This privacy policy was last updated on: 11/06/2020

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 privacy policy cover?

This privacy policy explains how and why redwigwam processes your personal data and under the General Data Protection Regulations (GDPR) and Data Protection Act 2018.

redwigwam takes the security and privacy of your data seriously.  We need to gather and use information or “data” about you as part of our business and to manage our relationship with you.  We intend to comply with our legal obligations under the EU General Data Protection Regulation (GPDR) and the Data Protection Act 2018 in respect of data privacy and security.  We have a duty to notify you of the information contained in this policy.

redwigwam is a “data controller” for the purpose of your personal data.  This means that we determine the purpose and means of the processing of your personal data.  This policy applies to current and former employees, workers, volunteers, apprentices and consultants.  If you fall into one of these categories then you are a “data subject” for the purpose of this policy, you should read this policy alongside your contract of services and any other notice we issue from time to time in relation to your data.

We take your personal data very seriously, and this policy will explain how redwigwam will hold and process your information.  It explains your rights as a data subject.  It also explains your obligations when obtaining, handling, processing or storing personal data in the course of working for, or on behalf of, redwigwam.

  • 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.

redwigwam has separate policies and privacy notices in place in respect of worker applications, customers, suppliers and other categories of data subject.  This Policy does not form part of your contract of employment (or contract for services if relevant) and can be amended by redwigwam at any time.  It is intended that this policy is fully compliant with the 2018 Act and the GDPR.  If any conflict arises between those laws and this policy, redwigwam intends to comply with the 2018 Act and the GDPR.

What personal data do we process?

Personal data means information which relates to a living person who can be identified from that data (a data subject) on it’s own, or when taken together with other information which is likely to come into our possession.  It includes any expression of opinion about the person and an indication of how the intentions of us or others, in respect of that person.  It does not include anonymised data.

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.

We will collect and use the following types of personal data about you:

  • Recruitment information such as your registration, references, qualifications and membership of any professional bodies and details of any employment assessments;
  • Your contact details and date of birth;
  • The contact details of your emergency contacts;
  • Your gender;
  • Information about your assignments, start and end dates, role and location, working hours, details of salary;
  • Any other category of personal data which we may notify you of from time to time.

How do we process personal data?

redwigwam will process our personal data (including special categories of personal data) in accordance with our obligations under the 2018 Act.

Processing means any operation which is performed on personal data such as collection, recording, organisation, structure or storage; adaption or alteration; retrieval consultation or use; disclosure by transmission, dissemination or otherwise making available; restriction, destruction or erasure.

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 personal data?

redwigwam will process your personal data (including special categories of personal data) in accordance with our obligations under the 2018 Act.  Personal data means information which relates to a living person who can be identified from that data (a data subject) on its own, or when taken together with other information which is likely to come into our possession.

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.

We can process your personal data for these purposes without your knowledge or consent.  We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.

If you choose not to provide us with certain personal data you should be aware that we may not be able to carry out certain part of the agreement between us.  For example, if you do not provide us with your bank account details we may not be able to pay you.  It might also stop us from complying with certain legal obligations and duties which we have such as to pay the right amount of tax to HMRC or to make reasonable adjustments in relation to any disability you may suffer from.

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.

Who do we share your information with?

Sometimes we might share your personal data with a group companies or our contractors and agents to carry out our obligations under our contract of services with you or for our legitimate interest and legal requirements.

We require those companies to keep your personal data confidential and secure and to protect it in accordance with the law and our policies.  They are only permitted to process your data for the lawful purpose for which it has been shared and in accordance with our instructions.

We do not send your personal data outside the European Economic Area.  Should this change you will be notified of this and the protections which are in place to protect the security of your data will be explained.

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.

By signing up to redwigwam the data subject is entering a contract with redwigwam to either, find work or find a worker.  redwigwam will therefore process data in order to fulfil its side of the contract and offer the correct service.

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.

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.

How we protect your data.

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.

How to deal with data breaches

We have robust measures in place to minimise and prevent data breaches from taking place. Should a breach of personal data occur (whether in respect of you or someone else) then we must take notes and keep evidence of that breach. If the breach is likely to result in a risk to the rights and freedoms of individuals then we must also notify the Information Commissioner’s Office within 72 hours.

If you are aware of a data breach you must contact us@redwigwam immediately and keep any evidence you have in relation to the breach.

Subject access requests

 

Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them. This request must be made in writing.

If you would like to make a SAR in relation to your own personal data you should make this in writing to us@redwigwam. We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.

There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to 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.

© 2020 redwigwam