As an employment agency, PPLS processes personal data in relation to its own staff, work-seekers and individual client contacts. We abide by the principles of the Data Protection Act 1998 set out below.

PPLS holds data on individuals for the following general purposes:

• Staff Administration
• Advertising, marketing and public relations
• Accounts and records
• Administration and processing of work-seekers personal data for the purposes of work-finding services

The Data Protection Act 1998 requires PPLS as data controller to process data in accordance with the principles of data protection. These require that data shall be:

• Fairly and lawfully processed
• Processed for limited purposes
• Adequate, relevant and not excessive
• Accurate
• Not kept longer than necessary
• Processed in accordance with the data subjects rights
• Kept securely
• Not transferred to countries outside the European Economic Area without adequate protection.

Personal data means data, which relates to a living individual who can be identified from the data or from the data together with other information, which is in the possession of, or is likely to come into possession of, PPLS.

Processing means obtaining, recording or holding the data or carrying out any operation or set of operations on the data. It includes organising, adapting and amending the data, retrieval, consultation and use of the data, disclosing and erasure or destruction of the data. It is difficult to envisage any activity involving data, which does not amount to processing. It applies to any processing that is carried out on computer including any type of computer however described, server, desktop, laptop, pda etc.

PPLS reviews the data it holds on a regular basis to ensure that it is accurate, relevant and up-to-date and those people listed in the appendix are responsible for doing this.

PPLS only process data with the consent of the person whose data is held. By instructing PPLS to look for work and providing us with personal data contained in your registration information you will be giving your consent to PPLS, an employment agency, to process your details for work-finding purposes. If we intend to use your data for any other purpose we will request specific consent from you.

PPLS exercises caution before forwarding personal details of any of the individuals on which data is held to any third party such as past, current or prospective employers; suppliers; customers and clients; persons making an enquiry or complaint and any other third party.

Data in respect of the following is “sensitive personal data” and any information held on any of these matters will not be passed on to any third party without the express written consent of the individual:

• Any offence committed or alleged to be committed by them
• Proceedings in relation to any offence and any sentence passed
• Physical or mental health or condition
• Racial or ethnic origins
• Sexual life
• Political opinions
• Religious beliefs or beliefs of a similar nature
• Whether someone is a member of a trade union

Only the people listed in the appendix are permitted to add, amend or delete data from the database. However all staff are responsible for notifying those listed where information is known to be old, inaccurate or out of date. In addition all employees ensure that adequate security measures are in place.

Data subjects, i.e. those on whom personal data is held, are entitled to obtain access to their data on request and after payment of a fee. All requests to access data by data subjects will be referred to a director whose details are also listed on the appendix to this policy.

Any requests for access to a reference given by a third party will be referred to a director and treated with caution even if the reference was given in relation to the individual making the request. This is because the person writing the reference also has a right to have their personal details handled in accordance with the Data Protection Act 1998, and not disclosed without their consent. Therefore when taking up references an individual will be asked to give their consent to the disclosure of the reference to a third party and/or the individual who is the subject of the reference if they make a subject access request. However if they do not consent then consideration will be given as to whether the details of the individual giving the reference can be deleted so that they cannot be identified from the content of the letter. If so the reference may be disclosed in an anonymised form.

David Hulston

Claire Allden, Claire Hughes, Amanda Higgins, Grace Lee