Privacy Notice

HRNow Limited trading as HRNow referred to as ‘HRNow’, 'we' or 'our' is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us pursuant to the data protection (Jersey) law 2018 (“DPJL”).

HRNow is a "Data Controller" for their own data, which means we are responsible for deciding how we hold and use personal information. We are also registered with the Jersey Office of the Information Commissioner (“JOIC”) – Registration No. 18344.

When you engage HRNow to be your outsourced HR specialist and manage your HR requirements, HRNow are the “Data Processors”, the client will always remain the “Data Controller” of their own employee data.

We will comply with data protection law, the principles of which says that the personal information we hold about you must 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 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.
Keep your data only as long as necessary for the purposes we collected.
Keep securely.

HRNow is accountable to you and the Authorities to show compliance with (“DPJL”) and demonstrate how we are compliant.

The Data Protection Officer ("DPO")

We have appointed a DPO to oversee compliance with this Privacy Notice.

If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPO at DPO@hrnow.je.

You have the right to make a complaint at any time to the JOIC.

Contact details for these are outlined at the bottom of this Privacy Notice.

The Kind of Information We Hold About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

To explain this to you, we will list our different services when we collect or use additional information about you.

How Is Your Personal Information Collected?

Name
Title
Business Address
Identification documents

Telephone number
Email address
Signature
Bank details

What information do we collect about your Employees when you contact us to be your outsourced HR managers/advisors?

· CV data or test result data for recruitment and selection purposes.

· contractual data and pay data, benefits data, bonus data or pension data if we are required to consult on potential redundancies or run a redundancy process or a reward review process.

· technical competencies, appraisals, reviews or other individual performance data if we are required to support performance management issues.

· Where we provide a payroll function for the client, we will also hold salary and benefit information, social security, income tax and bank details.

· Identification documents.

· performance and disciplinary data if we are engaged to support such processes.

· individual skills scores or technical competencies if we are supporting a development plan, wider talent management process or wider strategy for training budgets and planning process.

· evidence and statements and witnesses and other factual performance measurements if we are required to support a grievance, bullying or harassment issue or a potential discrimination claim process.

· Bank details if we are providing payroll functions.

What Special Category Data do we collect about you?

HRNow do collect Special Category data from clients and their employees, when necessary, as part of their employment. The types of special category date can vary but will mainly consist of.

· sickness absence, potential disability or impairment data and wider medical history or diagnosis of health data if we are engaged to support a capability or absence management process.

· On rare occasions we may hold health information if an employee was diabetic or if employers are required to have “epi-pens” for employees with known allergies.

· baby due dates and any health-related issues regarding maternity or baby birth health concerns regarding IVF, maternity leave, parental leave, surrogacy, or adoption arrangements for clients.

· Doctor’s reports, accident reports containing injury details, hospital reports following accidents at work.

How We Will Use Information About You?

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

You have entered a Contract with us to provide you with a service; an example of this would be when you have engaged HRNow to manage your HR requirements.
We need to comply with a Legal Obligation; an example of this would be when we have to comply with lawful authority to disclose information to the Population Office or Tax Office with employee details or assist the Police with an investigation.
Where it is necessary for our Legitimate Interests (or those of a third party), your interests and fundamental rights do not override those interests. An example of this is when we make contact with your employees asking them to update their personal details on their HR files.

We will also use your personal information in the following situations, which are likely to be rare:

Where you have given your consent to contact you for a specific purpose, such as to receive marketing material about HRNow services.
In an emergency, it is in you and your employees’ vital interest for us to share information when we have it recorded; an example would be, if there was an incident at the workplace and we had to provide emergency services with the personal data of people on the office.

Change of purpose

We will only use your personal information for the purposes we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Data Sharing

We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests.

We use certain third parties also known as Processors to provide or support our services. We have appropriate agreements in place with those processors to ensure the safety of your information. For information on these processors please see the table below. We do not share your information with any processors for the purposes of direct marketing.

The current data processors used by HRNow are.

Processor	Description of processing	Link to Privacy Notice
Propelfwd	Data Protection Managers. They provide advice and assistance with our data protection requirements and have no access to your data. They will only act if you put in a data rights request or if we have a data incident/breach.	Privacy Notice - PropelFwd
MailChimp	We use this service for emailing you with information about our services or updates on HR related matters.	https://mailchimp.com/legal/privacy/
Eventbrite	We use this service to advertise or invite you to an event we are holding.	Eventbrite Privacy Policy \| Eventbrite Help Centre
Google Analytics	We use this to gain insight into the performance of our website, so we can identify areas where it may need improvement.	Privacy Policy – Privacy & Terms – Google
Breathe	This is a web-based HR database platform that we use for some of our clients.	Privacy Policy & Cookies (breathehr.com)
PeopleHR	This is a web-based HR database platform that we use for some of our clients.	Privacy Policy (peoplehr.com)
Office 365	This is our main system for processing and data storage.	Microsoft Privacy Statement – Microsoft privacy
HR4HR Recruitment Agency	This is our recruitment section where we collect various types of data to represent you as an employer or a candidate for employment.	HR Now Jersey / Privacy notice
Work Flow Max (Xero)	Time and billing software	Privacy Policy \| WorkflowMax by BlueRock (workflowmax2.com)
Manatal AL Recruitment	Recruitment software	Privacy Policy \| Manatal.com \| AI Recruitment Software
Workflowmax by BlueRock	This is a time management platform to assist with client invoicing.	Privacy Policy \| WorkflowMax by BlueRock
Core FocusX Limited	Website Developer	Privacy Policy - CorefocusX
Xero	Financial book-keeping software used to issue invoice and manage our accounts	Privacy Notice \| Xero

Processors are other organisations/services carefully chosen by HRNow to process your information correctly and securely. In the case of organisations outside of Jersey, the United Kingdom and the European Economic Area (EEA);

(a) we have prior written instructions for the transfer or

(b) we have entered into specific contractual terms with them to ensure that they treat your personal data in way equivalent to that in which they would be required if they were established in Jersey.

We use Office 365 and SharePoint to process and store our data. We have selected EEA storage locations for our data, so London, United Kingdom and the Netherlands, Europe are our preferred data storage locations with Office 365.
We ensure that your privacy rights are respected in line with this Notice and the same protection is given to your personal data as laid down by the DPJL.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Staff, Agents, Contractors and other third parties on a need to know basis.

They will only process your personal information on our strict instructions, and they are subject to a duty of confidentiality.

Details of these measures may be obtained from our DPO.

We have put in place procedures to deal with any suspected data security breach and notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

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 data. The purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements.

You can request our Data Retention Schedule from our DPO if required.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of Access, Correction, Erasure and Restriction

The personal information we hold about you must be accurate and current.

Please keep us informed if your information changes during your relationship with us.

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 right 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 right enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal information. This right enables you to ask us to delete or remove personal data where there is no good reason for us to continue 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 your personal information where we rely on a legitimate interest (or those of a third party). There is something about your situation that makes you want to object to processing on this ground. You also have the right to object to processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This right 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.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing or request that we transfer a copy of your personal information to another party, contact our DPO at DPO@hrnow.je.

You will not have to pay a fee to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your access request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

How to request your information and what we may need from you

You can use the Data Subject Access Request form, which is available on our Cookie Banner or click Here, to go directly to the data rights portal. If you have any questions about this process or any of your rights, contact our DPO at DPO@hrnow.je

You can also email your request and verbally make your request over the telephone to one of our team, whatever way you feel more comfortable with it.

We will need to request specific information from you to help us confirm your identity and ensure your right to access the information (or exercise any of your other rights).

We will respond to your request without undue delay, but certainly within Four Weeks after satisfactory verification of your identity. In some circumstances, we can apply an eight-week extension to this time frame if the request is complex in nature and cannot be answered in the four-week time frame. If this is to happen, we will inform you as soon as possible.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, contact our DPO at DPO@hrnow.je

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.

We may also notify you in other ways from time to time about the processing of your personal information or requesting you to confirm the accuracy of the information we hold on you.

Complaints

We want the chance to resolve any complaints you have about how we process your information. You have the right to complain to the JOIC about how we have used your data.

The details for each of these contacts are:

HRNow Limited
17 The Esplanade, St. Saviour, Jersey JE2 3QA
Telephone +44 (0) 1534 747559 or email DPO@hrnow.je

Jersey Office of the Information Commissioner
2nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT
Telephone +44 (0) 1534 716530 or email enquiries@jerseyoic.org

PERFORMANCE NOW