Company Name: ‘Proman’ is the trading name of all companies of the Proman group

including Proman Supply Chain Ltd, Proman Managed Services Ltd

and Proman Recruitment Ltd (‘the Company’)

Document DP4 Data Protection Procedure

Topic: Data Protection

Date: Aug 2020

Version: 1

Contents table:

• Introduction
• Definitions
• Data processing under the Data Protection Laws
• Information security
• Rights of the individual
1. The right to be informed
2. The right to access (‘subject access request’)
3. The right to rectification
4. The right to erasure (‘the right to be forgotten’)
5. The right to restrict processing
6. The right to data portability
7. The right to object to processing
8. Automated decision making processes
9. The right to withdraw consent
10. Timing and information to be provided to the individual
11. Charges
• Personal data breaches
• Record keeping
• Complaints
• Appendix
• Annex A

All organisations that process personal data are required to comply with data protection legislation.
This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data
Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals
certain rights over their personal data whilst imposing certain obligations on the organisations that
process their data.

As a recruitment business the Company collects and processes both personal data and sensitive
personal data. It is required to do so to comply with other legislation. It is also required to keep this
data for different periods depending on the nature of the data.

This policy sets out the Company’s procedures for implementing the Data Protection Laws. It should
be read in conjunction with the REC’s model Data Protection Policy.

Reviewed August 2022

In this policy the following terms have the following meanings:

‘consent’ means any freely given, specific, informed and unambiguous indication of an individual’s
wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the
processing of persona data relating to him or her;

‘data controller’ means an individual or organisation which, alone or jointly with others, determines
the purposes and means of the processing of personal data;

‘data processor’ means an individual or organisation which processes personal data on behalf of the
data controller;

‘personal data’* means any information relating to an individual who can be identified, such as by a
name, an identification number, location data, an online identifier or to one or more factors specific
to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural
person.

‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction,
loss, alteration, unauthorised disclosure of, or access to, personal data;

‘processing’ means any operation or set of operations performed on personal data, such as collection,
recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment
or combination, restriction, erasure or destruction.

‘profiling’ means any form of automated processing of personal data consisting of the use of
personal data to evaluate certain personal aspects relating to an individual, in particular to analyse
or predict aspects concerning that natural person’s performance at work, economic situation,
health, personal preferences, interests, reliability, behaviour, location or movements;

‘pseudonymisation’ means the processing of personal data in such a manner that the personal data
can no longer be attributed to an individual without the use of additional information, provided that
such additional information is kept separately and is subject to technical and organisational
measures to ensure that the personal data are not attributed to an identified or identifiable
individual;

‘sensitive personal data’* means personal data revealing racial or ethnic origin, political opinions,
religious or philosophical beliefs, or trade union membership, and the processing of genetic data,
biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s
criminal convictions. [Note 1]

* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’
except where we need to refer to sensitive personal data specifically.

‘supervisory authority’ means an independent public authority which is responsible for monitoring
the application of data protection. In the UK the supervisory authority is the Information
Commissioner’s Office (ICO).

All of these definitions are italicised throughout this policy to remind the reader that they are
defined terms.

Reviewed August 2022

The Company processes personal data in relation to its own staff, work-seekers and individual client
contacts and is a data controller for the purposes of the Data Protection Laws. The Company has
registered with the ICO and its registration number(s) are:

Proman Supply Chain Ltd Z5419938

Proman Managed Services Ltd ZB232120
Proman Recruitment Ltd ZA221732

The Company may hold personal data on individuals for the following purposes:

• Staff administration;
• Advertising, marketing and public relations;
• Accounts and records;
• Administration and processing of work-seekers’ personal data for the purposes of providing
work-finding services, including processing using software solution providers and back office
support (“Matchmaker”and “Tempaid”);
• Administration and processing of clients’ personal data for the purposes of
supplying/introducing work-seekers (“Matchmaker”);
• The training of work seekers of skills, knowledge or Client specific information and policies.

The Company will only process personal data where it has a legal basis for doing so (see Annex A).
Where the Company does not have a legal reason for processing personal data any processing will be
a breach of the Data Protection Laws.

Reviewed August 2022

Only those listed in the Appendix are permitted to add, amend or delete personal data from the
Company’s database(s) (‘database’ includes paper records or records stored electronically).

All Company staff are responsible for notifying those listed in the Appendix where information is
known to be old, inaccurate or out of date or a request for erasure, access, rectification or restriction
of processing has been received from the individual. Company staff are also responsible for notifying
those listed in the Appendix where any request for data portability, objection to processing or where
consent to process has been withdrawn and has been received from the individual.

The incorrect processing of personal data e.g. sending an individual’s details to the wrong person,
allowing unauthorised persons access to personal data, sending information out for purposes for
which the individual did not give their consent, or not having a lawful reason to process personal data,
may give rise to a breach of contract and/or negligence leading to a claim against the Company for
damages from an employee, work-seeker or client contact.

A failure to observe the contents of this procedure policy will be treated as a disciplinary
offence.

In addition all Company staff should ensure that adequate security measures are in place to limit the
risk of personal data breaches. For example:

• Staff should lock their computer screens when they are not in use.
• All devices, whether company or personal devices (including but not limited to computers, mobile
phones, other hand-held devices) containing personal data relating to the services of the Company
shall be encrypted and password protected. All personal data collected via a company or personal
device for the purposes of providing the Company’s services, should be processed through the
Company’s CRM and immediately removed from the device.
• Staff should not disclose their passwords to anyone.
• Email should be used with care. Company staff must ensure that emails are sent only to the
intended recipient/s. Where Company staff send an email in error then the email must be recalled
immediately and Company staff must inform those listed in the Appendix of the error so that any
risk of a personal data breach can be limited.
• Personnel files (whether for internal staff or work-seekers) and other personal data should be
stored securely to prevent unauthorised access. They should not be removed from their usual
place of storage without good reason.
• Personnel files (whether for internal staff or work-seekers) should always be locked away when
not in use and when in use should not be left unattended.
• Personal data should only be stored for the periods set out in the Company’s data retention policy.
• Processing includes the destruction or disposal of personal data. Therefore staff should take care
to destroy or dispose of personal data safely and securely. Such material should be shredded or
stored as confidential waste awaiting safe destruction.

Reviewed August 2022

An individual has the following rights under the Data Protection Laws:
1. The right to be informed of what information the Company holds on them – this is typically given
to the individual in a privacy notice;
2. The right of access to any personal data that the Company holds on them – this is usually referred
to as a ‘subject access request’;
3. The right to rectification of personal data that the individual believes is either inaccurate or
incomplete;
4. The right to erasure of their personal data in certain circumstances;
5. The right to restrict processing of their personal data;
6. The right to data portability of their personal data in specific circumstances;
7. The right to object to the processing of their personal data where it is based on either a legitimate
interest or a public interest;
8. The right not to be subjected to automated decision making and profiling; and
9. The right to withdraw consent where it was relied upon to process their personal data.

1. The right to be informed

Any individual whose personal data is processed by the Company will have the right to be informed
about such processing. They will have the right to be informed about who, what, where and why the
data is processed. This information should be delivered in a privacy notice, in writing and where
appropriate electronically. Depending on where the personal data are being collected, an individual
may be directed to the Company’s website privacy notice or be given a copy of a privacy notice. This
privacy notice should be issued in instances where either:

a) the Company collects/processes data directly from the individual; or

b) the Company has not collected/processed the data from the individual directly.

The privacy notice should include the information set out in Table 1 (below).

In addition:

a) Where personal data has been collected from the individual the privacy notice will need to be
issued at the point the data is collected. Where the Company intends to further process the
personal data for a purpose other than that for which the personal data was collected, the
Company shall provide the individual, prior to that further processing, with information on that
other purpose and with any relevant further information in an updated privacy notice.

b) Where personal data has not been obtained from the individual, the Company shall provide the
privacy notice within a reasonable period after obtaining the personal data, but at the latest within
one month, having regard to the specific circumstances in which the personal data are processed.
If the personal data are to be used to communicate with the individual then the privacy notice will
be issued at the time of the first communication with the individual. If a disclosure to another
recipient is envisaged, then the privacy notice will be issued to the individual at the latest when
the personal data are first disclosed.

Reviewed August 2022

Company staff will be responsible for issuing privacy notices to individuals whose personal data is
processed by the Company in the timeframes and circumstances mentioned above.

Reviewed August 2022

Table 1: Privacy information to be given to the individual
Where the Company Where personal data
collects data from the has not been
individual: obtained from the
individual:

• The identity and contact details of the Company and where Yes (Y) Y
applicable the controller’s representatives and/or data
protection officer.

• The purposes of processing and the legal basis for the Y Y

processing.

• The legitimate interest of the data controller or third party, Y Y

where applicable.

• The categories of personal data. No (N) Y

• Recipients or categories of recipients of personal data. Y Y

• Details of transfers to third countries and the safeguards in Y Y

place.

• The retention period of the data or the criteria used to Y Y

determine the retention period.

• The existence of individual’s rights including the right of Y Y

access, rectification, erasure, restriction of processing,
objection to processing and the right to data portability.

• The existence of the right to withdraw consent where it has Y Y

been given and relied upon.

• The right to lodge a complaint with the Information Y Y

Commissioner’s Office or any other relevant supervisory
authority.

• The source the personal data originates from and whether it N Y

came from publicly accessible sources.

• Whether the provision of personal data form part of a Y N

statutory or contractual requirement or obligation and
possible consequences of failing to provide the personal
data.

• The existence of automated decision-making, including Y Y

profiling and information about how decisions are made, the
significance and the consequences.

Reviewed August 2022

2. The right to access (‘subject access request’)

Individuals are entitled to obtain access to their personal data on request, free of charge except in
certain circumstances.

An individual will be entitled to the following information:

• Confirmation that their personal data is or is not being processed;

• Access to the personal data undergoing processing;
• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipient to whom the personal data have been or will be disclosed,
in particular recipients in third countries or international organisations;
• Where possible, the envisaged period for which the personal data will be stored, or, if not possible,
the criteria used to determine that period;
• The existence of the right to request from the Company rectification or erasure of personal data
or restriction of processing of personal data concerning the individual or to object to such
processing;
• The right to lodge a complaint with the ICO or any other relevant supervisory authority;
• Where the personal data are not collected from an individual, any available information as to the
source of that information;
• The existence of automated decision-making, including profiling, based on a public interest or a
legitimate interest and, at least in those cases, meaningful information about the logic involved,
as well as the significance and the envisaged consequences of such processing for the individual.

If the Company transfers the individual’s personal data to a third country or to an international
organisation, the individual shall have the right to be informed of the appropriate safeguards in place
relating to the transfer.

If the Company processes a large quantity of information concerning the individual making the
request, the Company might request that the individual specify the information or processing activities
to which the request relates to specifically before the information is delivered. If such a request is
required by the Company then it shall be delivered promptly to the individual, taking into
consideration the timeframes that subject access requests must be completed.

The individual’s right to access their information shall not adversely affect the rights and freedoms of
others and they will not be able to access the personal data of third parties without the explicit consent
of that third party or if it is reasonable in all the circumstances to comply with the request without
that third party’s consent, taking into consideration any means to redact the personal data of any third
party. Persons listed in the Appendix will decide whether it is appropriate to disclose the information
to the individual on a case by case basis. This decision will involve balancing the individual’s right of
access of their personal data against the third party’s rights in respect of their own personal data.

Note: an individual might not label their subject access request as such. Therefore Company
staff should always consider whether a request is a subject access request even when not
called that. If in doubt, refer to the persons listed in the Appendix.

Reviewed August 2022

3. The right to rectification

An individual, or another data controller acting on an individual’s behalf, has the right to obtain from
the Company rectification of inaccurate or incomplete personal data concerning him or her. The
Company must act on this request without undue delay.

Taking into account the purposes of the processing, the individual shall have the right to have
incomplete personal data completed, including by means of providing a supplementary statement
stating what they would require to be completed.

The Company shall communicate any rectification of personal data to each recipient to whom the
personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
The Company shall inform the individual about those recipients if he or she requests it.

Where the Company, acting as a data processor, receives information from a data controller to rectify
an individual’s personal data, then the Company shall comply with this request unless this proves
impossible or involves disproportionate effort.

In circumstances where the Company is unable to comply with the request as it proves impossible or
involves disproportionate effort, the Company will document this in a privacy impact assessment or
similar.

4. The right to erasure (‘right to be forgotten’)

An individual shall have the right to obtain from the Company, acting as data controller, the erasure
of personal data concerning him or her without undue delay. The Company will be obliged to erase
the individual’s personal data without undue delay where one of the following grounds apply:

• The personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed;
• An individual withdraws consent on which the processing is based, and where there is no other
legal ground for the processing;
• An individual objects to the processing (based on either a public interest or a legitimate interest)
and there are no overriding legitimate grounds for the processing, or an individual objects to the
processing for direct marketing purposes (including profiling related to direct marketing);
• The personal data have been unlawfully processed;
• The personal data have to be erased for compliance with a legal obligation; or
• The personal data have been collected in relation to the offer of information society services to a
child.

Where the Company, acting as data controller, has made the personal data public and is obliged to
erase that personal data, the Company, taking into account available technology and the cost of
implementation, shall take reasonable steps, including technological measures, to inform data
controllers which are processing the personal data that an individual has requested the erasure by
such controllers of any links to, or copy or replication of, those personal data.

The Company will not be obliged to erase information to the extent that processing is necessary:

• For exercising the right of freedom of expression and information;

Reviewed August 2022

• For compliance with a legal obligation which requires processing, or for the performance of a task
carried out in the public interest or in the exercise of official authority vested in the Company
acting as controller;
• For reasons of public interest in the area of public health;
• For archiving purposes in the public interest, scientific or historical research purposes or statistical
purposes; or
• For the establishment, exercise or defence of legal claims.

The Company shall communicate any erasure of personal data to each recipient to whom the personal
data have been disclosed, unless this proves impossible or involves disproportionate effort. The
Company shall inform the individual about those recipients if an individual requests it.

Where the Company, acting as a data processor, receives information from a data controller to erase
an individual’s personal data the Company shall comply with this request, unless this proves
impossible or involves disproportionate effort.

In circumstances where the Company is unable to comply with the request as it proves impossible or
involves disproportionate effort, the Company will document this in a privacy impact assessment or
similar.

5. The right to restrict processing

An individual will have the right to obtain from the Company, acting as a data controller, the restriction
of processing his or her personal data where one of the following applies:

• The accuracy of the personal data is contested by the individual, for a period enabling the
Company to verify the accuracy of the personal data;
• The processing is unlawful and the individual opposes the erasure of the personal data and
requests the restriction of their use instead;
• The Company no longer needs the personal data for the purposes of the processing, but they are
required by an individual for the establishment, exercise or defence of legal claims;
• The individual has objected to processing (on the grounds of a public interest or legitimate
interest) pending the verification whether the legitimate grounds of the Company override those
of the individual.

Where processing has been restricted, such personal data shall, with the exception of storage, only be
processed with the individual’s consent or for the establishment, exercise or defence of legal claims
or for the protection of the rights of another natural or legal person or for reasons of important public
interest.

Where an individual who has successfully asked for their personal data to be restricted, then the
Company will inform the individual before such a restriction is lifted.

The Company shall communicate any restriction of processing to each recipient to whom the personal
data have been disclosed, unless this proves impossible or involves disproportionate effort. The
Company shall inform the individual about those recipients if he or she requests it.

Where the Company, acting as a data processor, receives information from a data controller to restrict
processing an individual’s personal data, the Company shall comply with this request, unless this
proves impossible or involves disproportionate effort.

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In circumstances where the Company is unable to comply with the request as it proves impossible or
involves disproportionate effort, the Company will document this in a privacy impact assessment or
similar.

6. The right to data portability

An individual has the right to receive any personal data concerning him or her, which he or she has
provided to the Company, in a structured, commonly used and machine-readable format and have the
right to transmit those data to another data controller where:

• The processing is based on the individual’s consent or a contract; and

• The processing is carried out by automated means.

Company staff will advise those listed in the Appendix when they receive a request to port data. Those
listed in the Appendix will be responsible for identifying if the above circumstances are satisfied for
the purposes of porting the data to the individual and/or another data controller.

For the avoidance of doubt, there is no obligation to port personal data that is not kept by automated
means by the Company.

7. The right to object to processing

An individual, has the right to object to their personal data being processed or profiled based on a
public interest or a legitimate interest.

Where the Company receives an objection to processing or profiling on the above, those listed in the
Appendix will ensure that the processing and/or profiling ceases unless such persons can establish
compelling grounds to continue to process the personal data. If this is the case those persons listed in
the Appendix will document this in a privacy impact assessment or similar.

8. Automated decision making processes

An individual has the right not to be subjected to an automated decision making process, including
profiling, that produces a legal effect or a similarly significant effect on the individual.

However, it is possible to subject an individual to automated decision making processes, including

profiling, where:

a) It is necessary for entering into or performance of a contract between the employer and the
individual;
b) It is authorised by law; or
c) The individual has given their explicit consent.

Where a) and c) apply the Company will ensure that suitable measures are in place to safeguard the
individual’s rights and freedoms and legitimate interests, under both Data Protection Laws and the
Human Rights Act 1998, before this type of processing occurs for personal data.

Where a) to c) apply the Company will only process sensitive personal data where the Company has
received either the explicit consent to do so or there is a substantial public interest to do so. Again the
Company will ensure that suitable measures are in place to safeguard the individual’s rights and

Reviewed August 2022

freedoms and legitimate interests, under both Data Protection Laws and the Human Rights Act 1998,
before this type of processing occurs for sensitive personal data.

The safeguarding measures include:

• Conducting a risk assessment as to what risks are posed to the individual’s rights and
freedoms;
• Ensuring where the automated decision making process is necessary for entering into or
performance of a contract, that this is documented clearly by the Company;
• Ensuring where explicit consent is given this is documented clearly by the Company.

Company staff will be responsible for implementing the above safeguarding measures.

9. The right to withdraw consent

Where the Company relies on an individual’s consent to process their personal data then the Company
will advise the individual that they have the right to withdraw his or her consent at any time.

Any Company staff who receives a request from an individual to withdraw their consent to processing
their data will be responsible for issuing the individual with the Company’s withdrawal of consent
form. Once the form has been completed it should be given to the persons listed in the Appendix to
process the individual’s request further.

10. Timing and information to be provided to the individual

The Company shall provide information on action taken or not taken with regards to the individual
data protection rights, set out in paragraphs 1 to 9 inclusive, without undue delay and in any event
within one month of receipt of the request. Where the Company does take action, then it may, where
necessary, extend this period by a further two months, taking into account the complexity and number
of the requests. Those persons listed in the Appendix shall inform an individual of any extension within
one month of receipt of the request, together with the reasons for the delay. Where the Company
does not take action on the request of the individual then those persons listed in the Appendix will
inform him or her on the possibility of lodging a complaint with the ICO and seeking a judicial remedy.

11. Charges

Where requests from an individual are manifestly unfounded or excessive, in particular because of
their repetitive character, the Company may either:

• Charge a reasonable fee taking into account the administrative costs of providing the information
or communication or taking the action requested; or
• Refuse to act on the request.

The Company must demonstrate whether the request is manifestly unfounded or excessive. Those
listed in the Appendix will be responsible for demonstrating this.

Where the individual makes the request by electronic means the Company shall provide the
information in a commonly used electronic form, unless otherwise requested by the individual.

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The Company will need to act on any personal data protection breach it suspects or knows of when
acting as either a data controller or a data processor.

Company staff must inform those persons listed in the Appendix where a personal data breach has
either been reported to him or her or they themselves have identified a personal data breach.

1. Personal data breaches where the Company is the data controller:

Those listed in the Appendix will take measures to establish whether or not a personal data breach
has occurred. Those persons will:

• Conduct any relevant interviews or investigations of the Company’s practices and/or Company
staff to assess how the personal data breach occurred;
• Implement measures and take steps to limit, contain and recover the breach;
• Monitor

Unless the personal data breach is unlikely to result in a risk to the rights and freedoms of an individual,
then those listed in the Appendix will be responsible for alerting the ICO of any personal data breach
without undue delay, but no later than 72 hours after having become aware of the Company’s personal
data breach. Where it is not possible to inform the ICO in this time those listed in the Appendix will be
responsible for explaining to the ICO the reasons for the delay.

If the personal data breach happens outside the UK then those listed in the Appendix will be
responsible for alerting the relevant supervisory authority in the effected jurisdiction.

If those listed in the Appendix are not able to provide the ICO/other relevant supervisory authority
with all the relevant information related to the personal data breach then those persons shall provide
the information in phases without undue further delay.

Those listed in the Appendix will be responsible for documenting any personal data breaches,
including:

• The facts relating to the personal data breach – including any investigations undertaken or
statements taken from the Company’s staff;
• The effects of the personal data breach; and
• The remedial action taken.

2. Personal data breaches where the Company is the data processor:

Those listed in the Appendix will be responsible for alerting the relevant data controller as to the
personal data breach that has been identified as soon as they are aware of the breach, having
particular regard to any contractual obligations the Company has with the data controller.

3. Communicating personal data breaches to individuals

Where a personal data breach has been identified, which results in a high risk to the rights and
freedoms of individuals, those listed in the Appendix will be responsible for informing those individuals
effected by the personal data breach without undue delay.

For the avoidance of doubt there will be no need to inform individuals of a personal data breach
where:

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• The Company has implemented appropriate technical and organisational protection measures
to use the personal data affected by the breach, in particular to make the personal data
unintelligible to any person who is not authorised to access it, such as encryption.
• The Company has taken subsequent measures which ensure that the high risk to the rights
and freedoms of the individual is no longer likely to materialise.
• It would involve disproportionate effort to tell all affected individuals. Instead, those listed in
the Appendix shall, on behalf of the Company, make a public communication or similar
measure to tell all affected individuals.

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 Actions to take after a breach

Where there is a likely risk Where there is a high risk to

to individuals as a result of individuals as a result of the
the breach breach

Notify the individuals

Inform the ICO concerned as soon as is
reasonably feasible

When notifying individuals:

1. describe the nature of the breach;

2. give the name and details of the data protection
When a data controller notifies the ICO of a officer or other contact;
possible breach it must do the following: 3. describe the likely consequences of the breach;
and
1. describe the nature of the personal data 4. describe the measures taken or proposed to be
breach including where possible, the taken by the controller to address the breach,
categories and approximate number of data including, where appropriate, measures to
subjects concerned and the categories and mitigate its possible adverse effects.
approximate number of personal data
records concerned; The main purpose behind notifying an individual of
2. give the name and contact details of the a breach is to outline the specific steps they should
data protection officer or other contact take to protect themselves. However, there are
point where more information can be exceptions – communication with the data subject
obtained; shall not be required if:
3. describe the likely consequences of the
personal data breach; • The data controller has implemented appropriate
4. describe the measures taken or proposed technical and organisational protection measures
to be taken by the controller to address the and those measures were applied to the data
personal data breach, including where affected by the breach;
appropriate measures to mitigate its • The data controller has taken measures to ensure
possible adverse effects. that the high risk to the rights and freedoms of
data subjects is no longer likely to arise; or
• It would involve a disproportionate effort. In such a
circumstances, there shall be a public
communication whereby data subjects are
informed in an equally effective manner.

The information sent to individuals should be sent

separate to any other communication and could be
sent via multiple communication channels in order to
ensure transparency. The information should also be
presented in clear and plain language.

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Those listed in the Appendix will keep written records of the processing activities of the Company. The
records must be in writing (which can be in electronic form) and must include the following
information:
• The name and contact details of the data controller or data controller’s representative and
any joint controllers;
• The purposes of the processing;
• A description of the categories of the data subjects and of the categories of the personal data;
• The categories of recipients to whom personal data have or will be disclosed to, including to
those internationally;
• Any transfers of personal data internationally, including the identification of the third country
or international organisation to which the data is transferred;
• The envisaged time limits placed on an individual’s right to erasure; and
• Where possible, a description of the technical and security measures that have been utilised
to alleviate data-related risks.

The Company will also document:

• Information required for privacy notices;
• Records of consent;
• Controller-processor contracts;
• The location of personal data;
• Data Protection Impact Assessment reports;
• Records of personal data breaches;
• Information required for processing sensitive personal data or criminal convictions/offences
data.

The Company will make these records available to the ICO upon request.

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Where Company staff receive a complaint from an individual about the use of his or her personal data
then they should bring this to the immediate attention of those listed in the Appendix.

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The following individuals or groups of individuals are responsible for the following:

Responsibility Individual or group

Adding, amending or deleting personal data; All Group Company staff

Responding to subject access requests/requests The Data protection Officer (DPO) and the
for rectification, erasure, restriction data Compliance Team.
portability, objection, automated decision
making processes and profiling and withdrawal All Group Company staff are responsible for
of consent; communicating any and all requests they receive
to the DPO and/or the Compliance team.
Reporting data breaches/dealing with The Data protection Officer (DPO); or
complaints; and/or The IT & Network Manager

The Data protection Officer (DPO) for the Proman Group is;

Patrick Ramsdale
Director - The Proman Group
Building 2
Think Park
Mosley Road
Manchester
M17 1FQ

E: Patrick.Ramsdale@proman-uk.com

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a) The lawfulness of processing conditions for personal data are:
1. Consent of the individual for one or more specific purposes.
2. Processing is necessary for the performance of a contract with the individual or in order to
take steps at the request of the individual to enter into a contract.
3. Processing is necessary for compliance with a legal obligation to which the controller is subject
to.
4. Processing is necessary to protect the vital interests of the individual or another person.
5. Processing is necessary for the performance of a task carried out in the public interest or in
the exercise of official authority vested in the data controller.
6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a
third party, except where such interests are overridden by the interests or fundamental rights
or freedoms of the individual which require protection of personal data, in particular where
the individual is a child.

b) The lawfulness of processing conditions for sensitive personal data are:

1. Explicit consent of the individual for one or more specified purposes, unless reliance on
consent is prohibited by EU or Member State law.
2. Processing is necessary for carrying out data controller’s obligations under employment, social
security or social protection law, or a collective agreement, providing for appropriate
safeguards for the fundamental rights and interests of the individual.
3. Processing is necessary to protect the vital interests of the individual or another individual
where the individual is physically or legally incapable of giving consent.
4. In the course of its legitimate activities, processing is carried out with appropriate safeguards
by a foundation, association or any other not-for-profit body, with a political, philosophical,
religious or trade union aim and on condition that the processing relates only to members or
former members (or those who have regular contact with it in connection with those
purposes) and provided there is no disclosure to a third party without the consent of the
individual.
5. Processing relates to personal data which are manifestly made public by the individual.
6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever
courts are acting in their judicial capacity.
7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member
State law which shall be proportionate to the aim pursued, respects the essence of the right
to data protection and provide for suitable and specific measures to safeguard the
fundamental rights and interests of the individual.
8. Processing is necessary for the purposes of preventative or occupational medicine, for
assessing the working capacity of the employee, medical diagnosis, the provision of health or
social care or treatment or the management of health or social care systems and services on
the basis of EU or Member State law or a contract with a health professional and subject to
the necessary conditions and safeguards.
9. Processing is necessary for reasons of public interest in the area of public health, such as
protecting against serious cross-border threats to health or ensuring high standards of quality
and safety of healthcare and of medicinal products or medical devices, on the basis of EU or
Member State law which provides for suitable and specific measures to safeguard the rights
and freedoms of the individual, in particular professional secrecy.
10. Processing is necessary for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes, which shall be proportionate to the aim pursued,
respect the essence of the right to data protection and provide for suitable and specific
measures to safeguard fundamental rights and interests of the individual.

Reviewed August 2022