**PRIVACY POLICY**
**OUR CONTACT DETAILS**
Name: Platinum Nanny Ltd
Postal Address: Platinum Nanny Ltd, UK 3rd Floor Suite, 207 Regent Street, London, England W1B 3HH
E-mail: info@platinumnanny.com
Version: January 2024
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**DATA CONTROLLER AND SRI**
Platinum Nanny Ltd is the Data Controller responsible for your personal data. Our Senior Responsible Individual (SRI) is Holly Grattan, who can be contacted at info@platinumnanny.com or at the postal address provided above.
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**WHO WE ARE AND WHAT WE DO**
Platinum Nanny Ltd is a recruitment agency as defined in the Employment Agencies Act 1973. We are a business that finds candidates for employers but does not employ the candidates ourselves. We help match job seekers with potential employers.
We collect the personal data of the following types of people to allow us to undertake our business:
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers.
We collect information about you to carry out our core business and ancillary activities.
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**THE TYPE OF PERSONAL INFORMATION WE COLLECT**
**Candidate Data**
We currently collect and process the following information:
- Name
- Contact details such as email address and phone number
- Photograph
- Curriculum Vitae including employment history, educational details, and other relevant information
- Links to your professional profiles available in the public domain (e.g., LinkedIn, Twitter, business Facebook, or corporate website)
- Immigration status/Right to work/References/Qualifications/Criminal background as required by law for certain professions
- Start date/availability date
- Information on your interests and needs regarding future employment, both collected directly and inferred
- IP Address
- The dates, times, and frequency with which you access our services
- On occasion, we may collect and process the following information:
- Home Address
- National Insurance number
- Sex/Gender
- Date of Birth
- Marital Status
- References and referee details
- Emergency contact details
- Compliance documents regarding your personal service company
- Financial information pertaining to you or your personal service company, including bank details
- Extra information that you choose to tell us
- Extra information that your referees choose to tell us about you
**Client Data**
We currently collect and process the following information:
- **For Individual Clients (B2C):**
- Name
- Contact details such as email address and phone number
- Nationality
- Date of Birth
- Passport number
- Home address
- Residency status (to determine VAT invoicing requirements)
- Information and conversations relating to candidates introduced by Platinum Nanny Ltd
- Extra information that you choose to tell us
- **For Business Clients (B2B):**
- Name
- Contact details such as email address and phone number
- Business address
- Company incorporation details
- VAT number
- Information and conversations relating to candidates introduced by Platinum Nanny Ltd
- Extra information that you choose to tell us
**Supplier Data**
We currently collect and process the following information:
- Name
- Contact details such as email address and phone number
- Business address
- Company incorporation details
- Extra information that you choose to tell us
**Website Users**
When someone visits www.platinumnanny.com, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We collect data on the products you viewed or searched for, page response times, download errors, length of visits to certain pages, and page interaction information. This information is processed in a way that does not identify anyone.
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**HOW WE COLLECT PERSONAL INFORMATION AND WHY WE HAVE IT**
**Legal Basis for Processing Your Data**
We process your personal data under the following legal bases as provided under the UK General Data Protection Regulation (UK GDPR):
1. **Consent**: You have given clear consent for us to process your personal data for a specific purpose.
2. **Contractual Necessity**: Processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
3. **Legal Obligation**: Processing is necessary for compliance with a legal obligation to which we are subject.
4. **Legitimate Interests**: Processing is necessary for our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights.
**Our Legitimate Interests**
- **For Candidates**: Our legitimate interest is to find suitable job opportunities for you, as you are seeking work. Therefore, there is a legitimate interest to get in touch with you if we have open vacancies that suit your skills and experience.
- **For Clients**: Our legitimate interest is to fulfill your ongoing requirements to employ staff in your homes or businesses. There is a legitimate interest to get in touch with you to propose suitable staff applications and to inform you of updates in employment laws and relevant topics through our newsletter and blogs.
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**How We Collect Candidate Data**
Most of the personal information we process is provided directly by you:
- Sending your CV to Platinum Nanny Ltd or one of its employees
- Applying to a job on the Platinum Nanny Ltd website
- Registering and creating a profile on the Platinum Nanny Ltd website or signing up for job alerts
- Providing a hard copy of your CV
- Providing information directly to us as requested to fulfill our legal obligations
We also receive personal information indirectly from:
- Job boards where you have uploaded your CV and to which we subscribe
- Professional profiles such as LinkedIn where you have marked yourself as open to opportunities or accepted an InMail or connection request
- Public domain sources when searching for suitable candidates for a job role
- Your referees who may disclose personal information about you
**Why We Collect Candidate Data**
We collect and process candidate data to:
- Provide our recruitment services to you and facilitate the recruitment process
- Contact you in relation to job opportunities that may be of interest to you
- Update you on a current job application
- Stay up to date with your employment and skills
- Assess your data against current vacancies which we think may be suitable for you
- Enable you to submit your CV, apply online for jobs, or subscribe to alerts about jobs we think may be of interest to you
- Send your information to clients for opportunities when you have given us permission to do so (we always obtain your direct consent before sending your CV, contact details, and HR folders containing all employment and vetting documents supplied during registration to potential employers)
- Fulfill our legal obligations in relation to your recruitment
- Provide the correct information to our clients so that they can implement the correct payroll and invoicing for their employees
- Process your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you (with your consent)
**How We Collect Client Data**
We obtain client data directly from you when you contact us by phone, social media, and/or email, or when we contact you through business development activities. We may also collect client data from:
- The public domain such as your organization's website and other online sources
- Professional profiles such as LinkedIn
- Our partners, concierge companies, and real estate professionals
**Why We Collect Client Data**
We collect and process client data to:
- Provide our recruitment services to you and facilitate the recruitment process
- Contact you in relation to recruitment services we provide or can provide to you
- Keep a record of our conversations, meetings, and recruitment processes we are carrying out on your behalf, such as introductions, interview schedules, candidate trials, feedback, and offers
- Determine VAT invoicing requirements based on your residency status
- Process financial transactions, including invoicing and payments
- Process your data for the purpose of targeting appropriate marketing campaigns for our services and staying in touch through our newsletter
**How We Collect Supplier Data**
We obtain supplier data either directly from you when you contact us by phone and/or email or when we contact you through either email and/or phone where a member of your organization has given us your details.
**Why We Collect Supplier Data**
We collect and process supplier data to:
- Contact you in relation to our agreements
- Obtain support and services from you
- Perform certain legal obligations
- Process financial transactions, including invoicing and payments
- Keep a record of our interactions
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**WHO WE SHARE YOUR PERSONAL INFORMATION WITH**
We may share your personal information with:
- **Employees of Platinum Nanny Ltd**: To ensure we can provide our recruitment services effectively.
- **Clients**: To facilitate the job application process. We always obtain your direct consent either written or verbal before sending your CV, contact details, and HR folders containing all employment and vetting documents supplied during registration to potential employers. Once introduced, the Client is responsible for handling your personal data in compliance with data protection regulations.
- **Third-Party Service Providers**: Including our Applicant Tracking System (ATS) and Customer Relationship Management (CRM) providers, IT systems or software providers, IT support service providers, and document and information storage providers. All third-party service providers we use have entered into agreements with us to ensure they will not use your data outside the scope of the services they provide us.
- **Regulatory or Law Enforcement Agencies**: If we are required or permitted to do so by law.
- **Professional Advisors**: Including lawyers, bankers, auditors, and insurers providing consultancy, banking, legal, insurance, and accounting services.
- **Data Analytics and Search Engine Providers**: That assist us in the improvement and optimization of our site, but this is generally aggregated data and does not identify you personally.
We ensure that any third parties with whom we share your data are obliged to keep your details secure and to use them only to fulfill the service they provide to you on our behalf.
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### **INTERNATIONAL DATA TRANSFERS**
**Candidate Data Transfers Only**
We may transfer **candidate personal data** internationally under the following specific circumstances:
- **Specific Client Intent**: The transfer occurs only if one of our clients located outside the UK and EEA, specifically in countries like Saudi Arabia or the United Arab Emirates (Dubai), intends to consider employing you.
- **Express Consent**: The transfer happens solely with your **express consent** to send your personal data to that one specific client. We will inform you about the identity of the client and the nature of the position before obtaining your consent.
- **Limited Scope**: We do **not** transfer any other client data or your personal data to other parties internationally.
**Safeguards for International Transfers**
Given that these countries may not have data protection laws equivalent to those in the UK or EEA, we take the following steps to protect your personal data:
- **Explicit Consent**: Before transferring your data, we obtain your explicit consent after informing you of the possible risks due to the absence of adequate data protection safeguards in the destination country.
- **Confidentiality Agreements**: We require our international clients to handle your data confidentially and to use it only for the purposes for which it was provided.
**Your Rights and Choices**
You have the right to:
- **Be Informed**: We will provide you with clear information about the international transfer and the recipient of your data.
- **Withdraw Consent**: You can withdraw your consent to the international transfer at any time by contacting our SRI at info@platinumnanny.com. Please note that withdrawing consent may affect our ability to assist you with certain job opportunities.
**Compliance with Data Protection Laws**
While transferring your data internationally with your consent, we strive to ensure that your personal data is treated securely and in accordance with this Privacy Policy. We cannot guarantee that the destination country has data protection laws equivalent to those in the UK or EEA, but we make efforts to protect your data through confidentiality agreements and by limiting the use of your data to the agreed purposes.
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**HOW WE STORE YOUR PERSONAL INFORMATION**
We take appropriate measures to ensure your personal data is kept secure, including preventing it from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know.
**Data Security Measures**
We have implemented robust security measures to protect your personal data:
- **Encrypted Communications**: We use secure communication channels, including **WhatsApp**, which utilizes end-to-end encryption, to protect your data during transmission.
- **Access Controls**: Access to your personal data is limited to authorized personnel who need it for their job.
- **Encryption**: We use encryption technologies to protect your data during transmission and storage.
- **Secure Servers**: Your data is stored on secure servers protected by firewalls.
- **Regular Security Assessments**: We regularly review and update our security measures to ensure they remain effective.
**Communication Channels**
We may communicate with you through various channels, including email, phone calls, SMS, and messaging applications like **WhatsApp**. These communications may involve the collection and transmission of personal data necessary to provide our services.
**Data Retention**
We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for legal, accounting, or reporting requirements.
- **Candidates**: We will retain your data for two years from our last meaningful contact unless we are required by law to retain it for longer.
- **Clients**: We will retain your data for as long as we have an ongoing business relationship and for seven years thereafter, in compliance with tax and accounting regulations, unless required by law to retain it for longer.
- **Suppliers**: We will retain your data for as long as necessary to comply with our contractual obligations and for seven years thereafter, in compliance with tax and accounting regulations, unless required by law to retain it for longer.
If you request that we stop processing your data, we will keep a minimal amount of information about you to ensure that no further contact is made.
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**YOUR DATA PROTECTION RIGHTS**
Under data protection law, you have rights including:
- **Your Right of Access**: You have the right to ask us for copies of your personal information.
- **Your Right to Rectification**: You have the right to ask us to rectify personal information you think is inaccurate or incomplete.
- **Your Right to Erasure**: You have the right to ask us to erase your personal information in certain circumstances.
- **Your Right to Restriction of Processing**: You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- **Your Right to Object to Processing**: You have the right to object to the processing of your personal information in certain circumstances.
- **Your Right to Data Portability**: You have the right to ask that we transfer your personal information to another organization or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
**How to Exercise Your Rights**
Please contact our Senior Responsible Individual (SRI), Holly Grattan, at info@platinumnanny.com if you wish to make a request.
**Withdrawal of Consent**
Where you have provided consent to us processing your personal data, including consent for international data transfers, you have the right to withdraw that consent at any time. To withdraw your consent, please contact our SRI at info@platinumnanny.com.
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**NO AUTOMATED DECISION-MAKING**
We do not use your personal data for any automated decision-making processes, including profiling, that have legal or similarly significant effects on you.
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**COOKIES AND ONLINE TRACKING**
We use cookies to enhance your experience on our website. Our Cookie Policy is available [here](#) and is displayed when you visit our website. You can manage your cookie preferences at any time.
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**CHILDREN'S DATA**
We do not collect or process personal data from individuals under the age of **18**.
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**MARKETING COMMUNICATIONS**
We will only send you direct marketing communications where we have your explicit consent. This includes updates on employment laws, relevant topics through our newsletter, and blogs. You can opt-out of receiving such communications at any time by clicking the unsubscribe link in our emails or by contacting us at info@platinumnanny.com.
Our marketing communications are managed through Mailchimp, which is highly compliant with GDPR regulations.
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**EMPLOYEE DATA**
We collect and process personal data of our employees, consultants, and temporary workers in accordance with our internal policies and applicable data protection laws. A separate Employee Privacy Notice is available upon request.
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**OBLIGATION TO PROVIDE DATA**
Providing your personal data is voluntary. However, if you do not provide the information requested, we may not be able to provide you with our recruitment services or fulfill our obligations to you.
For clients, certain personal data is necessary to comply with legal and tax obligations, such as determining VAT invoicing requirements.
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**THIRD-PARTY LINKS**
Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share data about you. We are not responsible for the privacy practices of these third-party sites. We encourage you to read the privacy policies of every website you visit.
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**DATA BREACH NOTIFICATION**
In the event of a data breach that poses a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you without undue delay.
We will also contact any individuals or organizations who have received your data in error and request that they delete it immediately.
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**CHANGES TO THIS PRIVACY POLICY**
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes.
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**HOW TO COMPLAIN**
If you have any concerns about our use of your personal information, you can make a complaint to us at info@platinumnanny.com.
You can also complain to the Information Commissioner's Office (ICO) if you are unhappy with how we have used your data.
**The ICO’s Address:**
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: [https://www.ico.org.uk](https://www.ico.org.uk)
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**THIS UPDATE INCLUDES CHANGES INTRODUCED BY THE DATA PROTECTION AND DIGITAL INFORMATION BILL (2024)**
This policy reflects changes such as the replacement of the Data Protection Officer (DPO) with a Senior Responsible Individual (SRI) and stricter requirements for handling Subject Access Requests (SARs).
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**CONTACT**
Questions, comments, and requests regarding this privacy notice are welcomed and should be addressed to our Senior Responsible Individual (SRI), Holly Grattan, at info@platinum
