Launch Human Capital Management Ltd
Website Privacy Statement
This privacy statement explains how Launch Human Capital Management Ltd processes your personal data. It describes, in general terms, how we fulfil our data protection responsibilities for you. The scope of this statement covers all related activities by the staff of Launch Human Capital Management Ltd, to be referred to as Launch HCM hereafter.
The Role of Launch HCM in data protection terms is that of a data controller where it determines the purpose and use of the personal data being processed. Once received it becomes the privacy manager (PM) contactable using email@example.com, who will ensure that it is processed in accordance with the latest UK data protection legislation.
The sort of personal data processed by Launch HCM will be your basic contact details as the main point of contact for your business. The information being requested will be kept to a minimum and will only be used in relation to the provision of our services we are providing you. Your personal data will only be processed in the UK and on servers based in the EU.
Launch HCM’s duty of confidentiality means that our staff will treat your personal data with respect and in confidence. It will only be disclosed to staff that need to know it. We also expect the same duty of confidentiality of all third parties with whom we share personal data. We use appropriate organisational and technical measures to secure all personal data.
Launch HCM processes personal data against a lawful basis in instances described below:
• We will respond to your general enquiries in pursuit of our legitimate interests
• To comply with our legal obligations when applicable
• When necessary for the performance of a contract with you and its prior preparation
• When processing for a pre-defined purpose, for which your consent will be sought prior to that processing commencing
• In all cases the processing of personal data by Launch HCM shall be done in accordance with the principles of data protection as set out in the UK data protection legislation.
Launch HCM will share personal data, but only when necessary, with some or all of the following third parties:
• The Inland Revenue (HMRC) for invoice purposes
• Accountants appointed by Launch HCM
• Contractors/ service professionals appointed by Launch HCM
• SD Worx (parent company)
Launch HCM follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:
- General correspondence that does not lead to a contract will be retained for one year after our last contact with you
- Personal data collected for the preparation of a contract will be retained throughout contract plus 2 years after its completion
- Minimal contact data is stored indefinitely although all requests for erasure will be considered and actioned appropriately
- Financial records and invoices, which may include personal data, will be retained for 6 years after the end of the current tax year of processing
- By exception, documentation that includes personal data may be retained by Launch HCM beyond the schedule, but only for a specific purpose and only when Launch HCM believes there is a legitimate interest or a legal obligation to do so
At the end of the retention schedule Launch HCM will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. Launch HCM allows up to 3 months after the retention schedule to complete this action.
The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations), For convenience, these rights are shown below:
- Right to be informed as to how your personal data is being processed by us – this is done through this statement or specific privacy notices that may be issued separately
- Right to access your personal data held by us which is done by making a ‘Data Subject Access Request’ (DSAR) to the Launch HCM privacy manager
- Right to rectification of your personal data if you believe Launch HCM has collected or recorded it incorrectly or it needs to be updated
- Right to erasure of your personal data for which we no longer have a legitimate purpose to process or where your interests outweigh our own
- Right to restrict processing under certain circumstances, during which time your personal data but will not be in operational use until the related matter is resolved
- Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract
- Right to object to Launch HCM processing your personal data for which there is no associated legal or contractual obligation
- Rights related to automated decision making and profiling (however Launch HCM does not use these techniques in its decision making)
Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk.
Raising concerns, exercising rights or making queries about our processing of personal data can be done by contacting the privacy manager. Please be aware that we will need to verify your identity before responding fully, therefore, you may be asked for proof of your ID. Alternatively, you may wish to contact the ICO directly, using the details provided above, but naturally we would welcome the opportunity to handle any concerns you have first.