Privacy Policy
Data controller
Shareb Affiliates Limited is the data controller for the purposes of the General Data Protection Regulation 2016/679 and Data Protection Act 2018.
Personal data collected
Clients
When providing our employment rights enforcement services ("employment services"), we, Shareb Affiliates Limited, collect our respective clients' full name, postal address, email address, telephone number, and employment history for the last 6 years where necessary and appropriate. Employment history collected may include the name of our clients' respective employer in the relevant period, job titles, job descriptions, employment contracts, remuneration rates and payment dates, attendance details, relevant correspondent between the parties to the dispute, and any other information necessary to properly perform the respective contracts entered into with our clients.
When providing our bespoke services outside of employment law, we collect our respective clients' full name, postal address, email address, telephone number, and any other information necessary as applicable, in order to properly perform the respective contracts. Such other information may include for example, clients' National Insurance number, and details of their state benefits claims or other disputes for which our assistance is requested for resolution. The personal data we collect in such circumstances is limited to personal data essential to properly perform the respective contracts.
Non-clients
Our collection of personal data is limited where individuals are not engaged as our clients. We may receive personal data from non-clients as a result of email or postal enquiries made by non-clients. In such circumstances, we may receive personal data voluntarily disclosed by non-clients. Personal data collected from non-clients may include email addresses, name, telephone numbers or any other details voluntarily provided by non-clients in their enquiry. Personal data received from non-clients is solely used for the purposes of responding to specific enquiries of non-clients.
Methods of collection of personal data
Clients
We collect our clients' at the point of registration for our services, and subsequent engagement with other parties to our clients' respective dispute. Government parties may, for example, include employers, Advice, Conciliation and Arbitration Service (ACAS), employment tribunals, government departments responsible for processing benefit claims. We may collect personal information in the course of telephone conversations with clients which may be recorded.
Non-clients
We collect personal data of non-clients by way of enquiries and registration forms received by post or email. Where a registration form is received by a non-client without a contract having been entered into as a result, the registration form is deleted after a period of 3 months. We may collect personal information in the course of telephone conversations with non-clients which may be recorded.
Purposes of collection of personal data
When providing our employment services, we collect and process personal data so far as necessary to assess the merits of our clients' potential employment tribunal claim, to pursue such claims where instructed by our clients, and for effective communication purposes with involved parties therein.
When providing our bespoke services, we collect and process personal data so far as necessary to assess the merits of our clients' potential claim, and for effective communication purposes with involved parties therein in seeking satisfactory resolution on our clients' behalf.
We may process personal data for marketing purposes when sending promotional offers and information to consenting clients.
Sharing of personal data
When providing our employment services, we may share our clients' personal data with ACAS, employment tribunals, employers and employers' respective legal representatives where applicable and necessary in the claim process.
In all cases, when providing our services, we may share personal data with data processors that contractually provide us with mail handling and information technology services and infrastructure respectively. All personal data processed or held by our data processors is treated as confidential commercial information.
Information received from third parties
When providing our employment services, we receive personal data from our clients' respective employers and their legal representatives, ACAS, and employment tribunals in the course of assessing the merits of potential claims, and progressing claims of our clients' behalf.
When providing our bespoke services, we receive personal data from respective organisations party to the specific dispute with our clients.
Length of retention of personal data
Clients
For the purposes of pursuit or defence of potential legal claims, we retain clients' personal data for 6 years following their registration for our services, or where applicable, the conclusion of their respective dispute, whichever date is later.
Non-clients
Where no contract is entered into as a result of email or postal enquiries, or completed registration forms, the retained personal data is deleted from our systems 3 months following receipt of the personal data.
Cookies
We currently use no cookies on our website.
Security of personal data
We store personal data on secure servers which are backed up regularly. All paper based personal data is stored securely. Our security arrangements are under continual review for potential improvement.
Your rights
Withdrawal of consent
You may at any time withdraw your consent for our processing of your personal data which you previously consented to. In such circumstances we will cease processing your personal data. However, if we consider our continued processing of your personal data is necessary for our compliance with a legal obligation, or for the establishment, exercise or defence of legal claims, we shall provide a written response explaining our reasoning.
Subject access
You have a right to access your personal data we hold. You may access your personal data we hold by making a written request. We shall provide a copy of requested personal data usually within 28 days of receipt of the request. Where we are unable to provide a copy of requested personal data within 28 days, we will within the said period, provide written notification of our reasons for our inability to provide the personal data within 28 days, and where applicable, provide a reasonable date by which the data will be supplied as requested. We provide requested personal data free of charge unless a request for the same information was previously made.
Rectification
You have the right to rectification of personal data retained which infringes the law of the European Union or United Kingdom, or where you have withdrawn consent for processing. Your right may be exercised by providing us with a written request for rectification. Upon receipt of such a request, we shall reply within a reasonable time frame either confirming the correction of the personal data. If our continued retention of the non-rectified personal data is considered necessary for our compliance with a legal obligation, or for the establishment, exercise or defence of legal claims, we shall provide a written response explaining our reasoning.
Objections to processing
You may object to our processing of personal data by providing us with written notification of your objections. If, following receipt of an objection, we are unable to cease the processing for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims, we shall provide a written response explaining our reasoning.
Right to be forgotten
You have a "right to be forgotten" where our retention of personal data infringes European Union or United Kingdom law. In such circumstances you may request that your personal data is permanently removed from our systems. We shall comply with such requests unless we consider retention of the personal data necessary for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims. Where we consider retention of personal data necessary, we shall explain our reasoning in a written response.
Data portability
Where possible, and upon your express request, we may transfer your personal data we hold to another organisation.
Automated decision making
You have the right not to be subject to decision based solely on automated processing. We make no decisions based on automated processes.
Complaints
In the event that you are unhappy with the manner of our processing of your data, you may file a complaint with the Information Commissioner's Office ("the ICO") at: www.ico.org.uk.
Contact us
If you wish to exercise your rights set out above, or submit a privacy query, please contact us by post at:
Shareb Affiliates Limited, 7 Bell Yard, London, WC2A 2JR; and by email at: privacy@shareb.co.uk.
Shareb Affiliates Limited
29 November 2019