This privacy notice sets out our commitment to safeguarding the privacy of all clients and individuals who interact with Cultura HR Limited (“we/us/our”).
This notice explains how we apply the data protection principles and the rights afforded by the UK General Data Protection Regulation (“UK GDPR”) to the personal data that we process.
Our Role as Data Processor
When providing HR consultancy services to employer-clients, Cultura HR Limited acts as a data processor. We process personal data only on the documented instructions of the data controller, which is the employer engaging our services.
Where we hold or access personal data in the course of providing consultancy services (including disciplinary, grievance, investigation, advisory or case-management support), we do so strictly on behalf of the data controller.
Because of this:
· any request to access, correct, delete, restrict, or otherwise exercise your data protection rights in relation to personal data processed by Cultura HR on behalf of an employer must be made directly to the employer, as the data controller.
· we will not respond directly to such requests unless and until we are instructed to do so by the data controller.
· we will not respond directly to such requests unless and until we are instructed to do so by the data controller.
Your Personal Data
“Your Personal Data” means any information that identifies you directly or indirectly, such as your name, address, date of birth, contact details, employment information, or any other information relating to your personal circumstances.
Your Personal Data may also include special category data, such as information relating to your health, ethnicity, or other sensitive characteristics.
Generally, personal data is collected in person, by email, via telephone, or through similar communication systems.
Your Rights
You have the right to request access to Your Personal Data, to request correction of inaccurate information, to request portability, and to request restriction or erasure of Your Personal Data.
However, where Cultura HR is acting as a data processor, these rights must be exercised through the data controller (your employer). We will only act on such requests when instructed by the data controller.
If you make a request directly to us that relates to data we process on behalf of an employer, we will notify the data controller and await their instruction.
The Basis Upon Which We Process Personal Data
Where Cultura HR acts as a data controller (for example, in relation to our own business administration, client management, or regulatory obligations), we process Your Personal Data on the following bases:
· Contractual necessity – where processing is required to deliver consultancy services to our clients.
· Legitimate interests – for example, responding to regulatory enquiries, maintaining business records, or seeking feedback.
· Legal or regulatory obligations – including obligations to insurers, professional bodies, or statutory authorities.
We collect and record Your Personal Data primarily from you, but may also obtain information from third parties such as identity verification services or publicly available sources.
Data Storage and Security
Your Personal Data may be stored in paper files or secure computer systems (including email, cloud storage, and hard drives). Access is restricted to employees and consultants where necessary to perform our services.
We do not anticipate transferring Your Personal Data outside the European Economic Area. We take reasonable steps to safeguard Your Personal Data, including secure email practices, password protection, encryption where appropriate, and secure postage for original documents.
Client data will be retained for a minimum of seven years, or longer where we have a legal right or obligation to do so.
Your Rights in Relation to Personal Data We Control
Where Cultura HR acts as a data controller, in relation to its own employees, employees may:
· request copies of their Personal Data under our control
· ask us to explain how we use their Personal Data
· ask us to correct, delete, restrict, or stop using their personal Data (subject to legal limitations)
· ask us to transfer their Personal Data to another organisation
· withdraw consent for marketing communications
If you wish to exercise these rights, please contact [email protected].
If we believe we have a legal basis not to comply with your request, we will explain this at the time.
You should notify us immediately if you become aware of any unauthorised disclosure of Your Personal Data.
Concerns or Complaints
If you have concerns about how we have handled Your Personal Data, you may lodge a complaint with the Information Commissioner’s Office (ICO) via https://ico.org.uk/global/contact-us/ or by writing to:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF.
ICO Registration
Cultura HR Limited is registered with the Information Commissioner’s Office (ICO) as a data controller under registration number: ZB576500.
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