Protection Policy inc GDPR

Purpose

Veltis Consulting Limited is committed to being transparent about how it collects and uses the personal data, and to meeting its data protection obligations. This policy sets out the Company’s commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of company directors, employees, workers, contractors, apprentices and former employees, referred to as HR-related personal data. In addition, it applies to the personal data of clients or other personal data processed for business purposes in so far as it provides guidance to employees on how such data should be treated.

The Company has appointed Rajeev Mahajan, Director as its Data Protection Officer. This role is to inform and advise the Company on its data protection obligations. They can be contacted at info@veltis.ie. Questions about this policy, or requests for further information, should be directed to the Data Protection Officer.

Our Commitment

In order to operate efficiently, the Company has to collect and use information about people with whom it works. These may include current, past and prospective employees, clients, customers, and third-party service provides. The Company is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the Company’s commitment to data protection, and individual rights and obligations in relation to personal data.

The Company regards the lawful and correct treatment of personal information as very important to its successful operations and to maintaining confidence between the Company and those with whom it carries out business. The Company will ensure that it treats personal information lawfully and correctly.

To this end the Company fully endorses and adheres to the Principles of Data Protection as set out in the Data Protection Act 1998 and The General Data Protection Regulations (2018).

The Principles of Data Protection

Definitions

“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data protection principles

The Company processes HR-related personal data in accordance with the following data protection principles:

The Company processes personal data lawfully, fairly and in a transparent manner.
The Company collects personal data only for specified, explicit and legitimate purposes.
The Company processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
The Company keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
The Company keeps personal data only for the period necessary for processing.
The Company adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

The Company informs individuals as to the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

Where the Company processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

The Company will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the employment or worker/contractor relationship, or apprenticeship is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which the Company holds HR-related personal data are contained in its privacy notices to individuals.

The Company keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, the Company will tell him/her:

whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
for how long his/her personal data is stored (or how that period is decided);
his/her rights to rectification or erasure of data, or to restrict or object to processing;
his/her right to complain to the Information Commissioner if he/she thinks the Company has failed to comply with his/her data protection rights; and
whether or not the Company carries out automated decision-making and the logic involved in any such decision-making.

The Company will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

The Company will normally respond to a request within a period of one month from the date it is received.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require the Company to:

rectify inaccurate data;
stop processing or erase data that is no longer necessary for the purposes of processing;
stop processing or erase data if the individual’s interests override the Company’s legitimate grounds for processing data (where the Company relies on its legitimate interests as a reason for processing data);
stop processing or erase data if processing is unlawful; and
stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the Company’s legitimate grounds for processing data.

To ask the Company to take any of these steps, the individual should send the request to the Company at info@veltis.ie.

Handling of Personal/Sensitive Information

The Company will through appropriate management and the use of strict criteria and controls:

Observe fully conditions regarding the fair collection and use of personal information (see Appendix 1

“Purposes Information”);

Meet its legal obligations to specify the purpose for which the information is used;
Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;
Ensure the quality of information used;
Apply checks to determine the length of time information is held;
Take appropriate technical and organisational security measures to safeguard personal information;
Ensure that personal information is not transferred abroad without suitable safeguards;
Ensure that the rights of people about whom the information is held can be exercised under the Act.

Company management and staff within the Company will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure and in particular will ensure that:

Paper files and other records or documents containing personal/sensitive data are kept in a secure environment;
Personal data held on computers and computer systems is protected by the use of secure passwords, which where possible have forced changes periodically;
Individual passwords should be such that they are not easily compromised.

Please refer to Appendix 1 – “Purposes Information” for further information which details the type of information that is held by the Company and the purpose for which it is held.

Employee Responsibilities

Individuals are responsible for helping the Company keep their personal data up to date. Individuals should let the Company know if data provided to the Company changes, for example if an individual moves house or changes his/her bank details.

Individuals may have access to the personal data of other individuals and of our customers and clients in the course of their employment or contract or apprenticeship. Where this is the case, the Company relies on individuals to help meet its data protection obligations to staff and to customers and clients.

Individuals who have access to personal data are required:

to access only data that they have authority to access and only for authorised purposes;
not to disclose data except to individuals (whether inside or outside the Company) who have appropriate authorisation;
to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
not to remove personal data, or devices containing or that can be used to access personal data, from the Company’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
not to store personal data on local drives or on personal devices that are used for work purposes
to obtain and process information fairly;
to keep it only for one or more specified, explicit and lawful purposes;
to use and disclose it only in ways compatible with these purposes;
to Keep it accurate, complete and up-to-date;
to ensure that it is adequate, relevant and not excessive;
to retain it for no longer than is necessary for the purpose or purposes

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the Company’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Any information about another employee, which you may come into contact with during the course of your employment, must be kept confidential and where appropriate, must be destroyed securely. Anyone disclosing personal data or using it for their own purposes without the authority of the Company, may commit a criminal offence unless there is some other legal justification for its disclosure. Their actions may also lead to disciplinary action, and in serious instances, dismissal.

If you have any questions in relation to your responsibilities under the Data Protection legislation, please contact us at info@veltis.ie.

Data security

The Company takes the security of HR-related personal data seriously. The Company has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where the Company engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Impact assessments

Some of the processing that the Company carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, the Company will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If the Company discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The Company will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

International data transfers

HR-related personal data may be transferred to countries outside the EEA to provide data to the Company’s pension provider or other third-party benefits provider as required.

Training

The Company will provide training to all individuals about their data protection responsibilities as part of the induction process.

Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.

Review

This policy will be regularly updated to ensure its effectiveness and compliance with current legislation.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

VELTIS CONSULTING LIMITED

Website: https://www.veltis.ie/

Email: contact@veltis.ie

Phone: +353 89 975 1143

Mobile: +353 87 338 5643

Address: 3 Butterstream Court, Academy Street, Navan, Ireland, C15 EF67

Last Updated: [04^th November 2024]

Appendix 1 – Purposes Information

Keeping information about you (non-contractual)

We need to keep information on file about you for normal employment purposes. The information we hold is for our management and administrative use only. We will keep and use this information to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, from the time you first apply for a job, whilst you are working for us, at the time when your employment ends and after you leave. This includes using information to enable us to comply with our contractual obligations and to protect our legal position in the event of claims against us. Much of the information we hold will have been provided by you, but some may come from other internal sources, such as your manager or, in some cases, external sources, such as referees.

The sort of information we hold about you

The sort of information we hold includes:

your application form/CV and references
your contract of employment and any amendments to it
documentation confirming your identity and your right to work legally in Ireland
correspondence with or about you, for example letters to you about a pay rise or, at your request, a letter to your mortgage company confirming your salary
information needed for payroll, benefits and expenses purposes
contact and emergency contact details
records of holiday, sickness and other absences
records relating to your career history, such as training records, appraisals, other performance measures and, where appropriate, disciplinary and grievance records
information about some of your protected characteristics for monitoring purposes only

If your job requires you to drive we must see your driving licence before you drive any Company vehicle.

Information about your health

Where necessary, we may keep information relating to your health. This information might include reasons for any absences and doctor’s reports and notes and will be used for the following:

to comply with our health and safety and occupational health obligations
to manage sickness absence and to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate
to administer and manage statutory and Company sick pay and any other relevant benefits, such as health insurance and life assurance schemes.

When we give information about you to third parties

We will only disclose information about you to third parties for the following reasons:

if we are legally obliged to do so
to comply with our contractual duties to you
to contractors who carry out some of our functions, such as to run our IT systems or payroll functions

where we transfer information about you to other Group Companies or to Group Head Office for purposes connected with your career or the management of the Company’s business upon your request