This privacy policy was last updated on: 24/05/2018

Who Are we?

RedWigWam is an online job booking platform, that matches workers profiles against jobs loaded by hirers.   The system also allows workers to complete reports and timesheets, check workers right to work and process payroll and invoicing.

We are UK based and our registered head office is based in Liverpool, The Landing Pad, 49 Jamaica Street, Liverpool, L1 0AH.

What does this policy cover?

We take your personal data very seriously, and this policy:

  • Sets out the types of personal data that we collect
  • Explains how and why we collect and use your personal data
  • Explains how long we keep your personal data for
  • Explains when, why and with who we share your personal data
  • Sets out the legal basis we have for using your personal data
  • Explains the effect of refusing to provide the personal data requested
  • Explains the different rights and choices you have when it comes to your personal data;

and explains how we may contact you and how you can contact us.

What personal data we collect

We ask our workers for specific pieces of information that allows us to match them to roles that may be relevant and an interest to them, the data collected also allows us to check and verify workers right to work in the UK and also to process payments directly into workers bank accounts.  Pieces of information volunteered by workers are required at different stages of the process but may be supplied earlier if the worker wishes to do so.

We also collect contact information for hirers, this includes accounts contact, office contact and if required a contact detail for a specific member of the team looking after a role.

RedWigWam does not collect any data that is not required by an identified process within the system.

Where do we  collect personal data?

Personal data is collected from workers through their profile on the RedWigWam system, workers have the ability to view all the information RedWigWam has for them, and workers are free to maintain, edit and delete any information which they do not want to share with RedWigWam.  RedWigWam may place adverts on popular job placement boards of social media, if you show interest or interact with the post, RedWigWam may follow up by contacting you using that media or other sources publicly available to discuss the opportunity or similar opportunity.

Our hirers data is also collected directly form the hirer inside their profile, and they have the ability to view, edit and delete any information which they do not want to share with RedWigWam.

RedWigWam may also reach out to prospectus employers by collecting their information from publicly available sources, such as:

  • A conference both the prospectus hirer and RedWigWam have attended
  • Media/News/Articles that list contact details for a prospectus hirer
  • Twitter, Facebook, LinkedIn, and any other social platform where a prospectus hirer may advertise a role and display publicly contact details and job requirements.
  • By reference or word of mouth, for example, you may be recommended by a friend/family member, a former employer, a current employer, a former/current employee or colleague.
  • From an agency/third party reaching out on your behalf.

How and why we use your information?

We use workers personal data to match your experience, skills, location, and travel preferences to roles that are suitable.  We collect this information from workers directly via their profile, if successful and if the role requires, RedWigWam may share pieces of your information with the client (Hirer) in order to deliver anything the worker may need to the role or to allow further communication between worker and hirer.  RedWigWam will only share pieces of information comprising of a combination of, Name, Address, Phone Number, Email Address.   Occasionally a role may require specific certification or a CV before the hirer will confirm the role, in these circumstances RedWigWam will contact the worker and agree with the worker how to collect and share this information.

We use workers biometric or identity data to compose a right to work check, as per guidance from the UK Government.  Every worker must complete this check before work is accepted, and the system will not allow anyone to bypass this check.   Bank details are used to process payroll.

We use hirers personal data to alert them to changes to their role, such as the role being booked and to confirm attendance the evening before.  We may also alert hirers of any special offers or points of interest from RedWigWam.

How long do we keep your personal data for?

We only retain your information for as long as is necessary to use your data for the reasons outline above, or to comply with our legal obligations.  You may remove your own account at any time using your profile, and you may request RedWigWam to action this for you.   However, please be advised we do have to retain some information for periods of time after you have ceased using our services if you have completed a role with us, this is a necessary for us to meet our legal obligations.

When determining the relevant retention periods, we will consider:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • our legitimate interest where we have carried out a balancing test (see legal basis below);
  • statute of limitations under applicable law(s);
  • (potential) disputes;
  • if you have made a request to have your information deleted; and
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information according to the following guidelines:

  • Two (2) years since you last signed into your account
    1. We will remove your bank details and remove you from our automatic mailing system
  • Three (3) years since you last signed into your account and you haven’t complete a role with us
    1. We assume you are no longer actively looking for a role and will remove your account and all your details
  • Five (5) years since you last signed into your account and you have completed a role with us
    1. We will remove your account and all of your details

Who do we share your information with?

Workers information is shared with some subprocesses with specific job functions that are integrated with RedWigWam, these include:

  • Payroll software which in turn integrates with HMRC
  • Facial recognition software
  • Hirers that need specific pieces of information

Data assessments and balancing has been conducted on each of the subprocesses and determined that we share only the core information required and that the data is processed only in the way it is intended and communicated with our workers.

Legal Basis for processing your data

As a temporary staff booking we will be processing data on the basis of legitimate interest, Contract and compliance with legal obligation.

Contract: GDPR Article 6:B

This article permits processing that is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

By signing up to RedWigWam the data subject is entering a contract with RedWigWam to either, find work or find a worker.  RedWigWam will therefor process data in order to fulfil its side of the contract and offer the correct service. to fully match the requirements set by the hirer to workers who are interested.

Compliance with a legal obligation: GDPR Article 6:C

This article permits the processing for the purpose the necessary for compliance with a legal obligation to which the controller is subject.

In compliance with UK employment law, RedWigWam has a legal obligation to pay workers for any worker undertook as per the T&C of RedWigWam.  As per the UK Home Office & HMRC RedWigWam is legally obligated to keep records of worker payments and working activity for a period of (5)Five years.  This data may be kept separate to RedWigWams active employees and any unnecessary information will be removed.

Legitimate interests: GDPR Article 6:F

This article permits the processing for the purposes of the legitimate interests pursued by the controller or by a third party.

It further states that you can process personal data without given consent if you have a genuine and legitimate reason (including commercial benefit), except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

By registering with RedWigWam workers are declaring an interest in recruitment. Workers are matched to roles based of the data collected from the worker and stored in the system. RedWigWam may send emails that include;

  • relevant matched roles
  • relevant information/news that could be of interest to the worker
  • Updates to the system

RedWigWam may collect the email address and name of hirers/potential hirers as we want to inform them of new products or services we are providing.   We may give this information to an organisation such as mail chimp who will send out our communication on our behalf.

What happens if you do not provide the data or request we stop processing your data?

If you do not provide us with the personal data required we not be able to match you to any available roles on our system.

If you withdraw your consent you must be aware that some data processing may still be required by RedWigWam to fulfil its legal obligations, once we have filled our legal obligation data processing will cease.

Do we make automate decisions concerning you?

We do not carry out any automated profiling.

Do we transfer your data outside of the EEA?

RedWigWam works with UK based companies, and has servers located inside the EEA, so no data is moved outside of the EEA.   If it would arise that a company had their head office or offices based outside the EEA, RedWigWam would ensure adequate data protection policies are in place, no less than what is required by the GDPR, to ensure the safety and integrity of your data, this data would only be transferred according to the above guidelines.

Keeping information secure

The importance of secure storage of your personal information is our main priority.  We exercise caution and great care when transmitting data we take all reasonable steps and keep up-to date with latest technological advances to be able to secure and protect your data.  Only employees who need access to your information in order to do their jobs are allowed access.  Any employee who violates our privacy and or security policies is subject to disciplinary action which ultimately may lead to dismissal and possible civil/criminal prosecution.  We take all reasonable steps to maintain and up-to date, accurate, complete, relevant for current workings and store securely.

RedWigWam is committed to ensuring your information is secure, in order to prevent unauthorised access or disclosure we have enforced physical, electronic and managerial procedures and processes to safe guard your information, we also take reasonable steps to ensure personal data is protected from misuse, inference, loss modification or disclosure.

What rights do you have regarding your data?

Whether you are aware or not, you have specific rights regarding your data and how it is used, the GDPR principles aim to move the focus more into your rights and how you exercise your rights should you wish to do so.

 

Right What does this mean?
The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your data and your rights in relation to the use of your data. That is the purpose of this privacy policy.
The right of access You have the right to obtain access to your information (if we’re processing it), and certain other information (like that provided in this Privacy Policy).  This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure This enables you to request the deletion or removal of your information where there is no compelling reason for us to continue using it. There are exceptions to the right to erasure.
The right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. A note will be made on your record to ensure the restriction is respected in the future.
The right to data portability You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to object to processing You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

 

Subject access requests may be made to RedWigWam, as per the GDPR, if subsequent, baseless, repeated, or requests for further copies are received we may charge a reasonable fee to cover our administrative costs, alternatively we may be entitled to refuse to act upon your request.

Do we use cookies to collect your personal data?

No, we do not use any cookies to collect your personal data, and no personal data is stored in our cookies.  Please see our cookie policy for more information.

Third-parties

We do not and will not sell any of your collected personal information to outside parties.

Third-party links

From time to time, RedWigWam make link workers to a service the hirer has requested results be sent to, or we may use a service to enhance our offering or allow for everyone to feedback to the RedWigWam community.  You will always be made aware when you are leaving the RedWigWam system.  You must check the privacy policy of these sites to ensure you are satisfied and happy to proceed.

How will we contact you?

We may contact you via Email, Phone, SMS, WhatsApp, App Notification, Social Media or in writing.  This could be for various reasons include:  Job matches, close job matches, updates and notices from the system and general marketing emails.  You can control your preferred methods of communication in your profile.

How can you contact us?

You can contact us in various different ways:

  • Live chat – this is our preferred method and has the fastest response times
  • By email – Emailing us@redwigwam.com
  • By post: Address, RedWigWam, 49 Jamaica Street, Liverpool, L10AH

If you are unhappy or feel let down

If you are unhappy or feel let down by anything we do, we have a complaints form which is accessed through the FAQ section.  Please fill this in and give as much detail as possible.

© 2018 RedWigWam