Contractor Conditions

PURPOSE
Raeburn Training is committed to protecting suppliers & subcontractors’ personal data.  This policy contains important information about what personal data we collect and why, how we use/store/protect data and, when required, how we share data with third parties.  It also contains information on suppliers and subcontractors’ rights in relation to their data.

This policy is subject to change, with the most recent version available from our Company website. 

COLLECTING DATA
Why we collect data

The Company takes privacy seriously and will only ever collect data which is personal to suppliers / subcontractors where it is necessary, fair and lawful to do so.  We will only collect and use information where:

• It is necessary as part of current/prospective contractual agreement / service
• You have given consent, when required by the business
• There is a legitimate interest for the purpose of a third-party service
• The Company must demonstrate legal compliance

What data is collected

• Information about suppliers / subcontractors connected to the contractual agreement/service: name, role, company name, bank details, insurances, training records, fitness to work
• Information through communications: text, calls, e-mails, letters, meetings.

It is important to note that Raeburn Training expect suppliers / subcontractors to provide the company with details pertaining to their representatives / workers when they have authority to do so in line with current data protection laws.

We do not require and will not accept excessive personal data pertaining to representatives / workers and concerns over this being provided will be highlighted directly with the supplier / subcontractor.

How data is collected
All personal data is obtained directly from the supplier/subcontractor through various methods throughout the contract/service with the company.  This can include via telephone, e-mail, attendance at meetings, texts etc.

STORAGE, SECURITY AND USAGE
The data we collect from suppliers/subcontractors is stored in various locations for different purposes throughout the engagement and, on occasion, afterwards.  These locations are typically accessible by management and administrative staff, depending on the process being executed and include:

In addition to the above security measures, all Raeburn Training employees involved in data collecting and processing will undertake annual training. Their systems and processes are also subject to regular audit to ensure continual compliance.

The Company prohibits the transfer of data from a Company device to a personal device.

Breaches of these guidelines will be treated as gross misconduct and investigated and actioned through our disciplinary policy.

SHARING
The Company will only share a suppliers / subcontractor’s data with a third party when necessary to meet a contractual or legal obligation.  Providers we typically share information with are in relation to the following processes:

• Payment of invoices – through financial systems / software.
• Verify training / qualifications by contacting providers.
• Reference checks by contacting listed referees.
• Relevant awarding bodies in relation to the courses delivered by the supplier / subcontractor.
• Social Media and Website (opt in required): promotion of past training events, testimonials etc.

DATA RETENTION
We will only keep personal information where it is necessary to fulfil our contractual obligation to suppliers / subcontractors as well as our legal obligation throughout the engagement.

If the contract is terminated by either party or when the contract comes to a natural end, the Company is obliged to retain certain information for legal purposes and the length of time of retention will vary depending on the obligation we are required to meet.

In addition to the above, the Company may wish to keep details on file for potential future engagement.  In this instance, again, approval will be sought from the supplier / subcontractor.  If approval is not received, details will automatically be removed from our system.

AUDITING
To ensure continued compliance, regular audits will be conducted in line with our Workplace Monitoring Policy, with all Raeburn Training employees involved in collecting and processing data required to fully participate and co-operate. 

Any breaches found will be rectified immediately and reported through the necessary channels within the relevant timescales.

YOUR RIGHTS
Suppliers / subcontractors have several legal rights to control what the Company does with their information.  This includes the right to:

• Access personal information
• Request that personal information is rectified
• Request erasure if there is not a compelling reason for the Company to have it
• Restrict processing for certain reasons where, again, there is not a compelling reason for the Company to do so
• Data portability so to use your own data across different services
• Object to data processing in relation to any marketing, interest of the company or research purposes
• Question automated decision making

In order to fully understand a data access request, the Company requests that the supplier / subcontractor completes the Data Request Form (appendix 4), however, this is not compulsory, and the supplier / subcontractor may choose to use another, written means to make the request.

An administration fee of £10.00 will apply for each request received.

HOW TO COMPLAIN
The Company will always strive to collect, use and safeguard supplier / subcontractor’s personal information in line with data protection laws.  If an individual does not believe the Company has handled information as set out in our Privacy Policy, please contact our Development Manager in the first instance who will aim to resolve the matter.

If an individual is still unhappy, they can complain to the Information Commission Office.