Privacy Policy

Scope and Overview
Drinx4u is committed to protecting the privacy and security of our personnel and their personal data. This Privacy Policy describes how we collect and process personal data about you during and after your employment or other working relationship with us.

This Privacy Policy describes the categories of personal data that we collect, how we use your personal data and when we may disclose your personal data to third parties. This Privacy Policy also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure and non-use (in certain circumstances) of your personal data.

We will only process your personal data in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes relating to your relationship with us.

This Policy applies to current and former employees, workers and contractors. It does not form part of any contract of employment or other contract to provide services.

Collection of Personal Data
“Personal data” means any information about an identifiable individual but excludes anonymous or de-identified data from which the individual cannot be identified or traced back. To carry out our activities and obligations as an employer, we may collect, store, and process the following categories of personal data, for the purpose of administering the employment/worker or contractor relationship with you and for you dealing with any of our external partners:
• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth
• Gender
• Marital and dependent status, (only when needed to administer benefits such as health insurance or pension benefits)
• Beneficiary and emergency contact information
• Government identification numbers such as national insurance number, driver's licence number, or other identification card number
• Bank account details and payroll information
• Wage and benefit information
• Performance information
• Insurance enrolment information
• Start date and job title/role
• Location of employment
• Education and training
• Employment records (including professional memberships, references, work history, and proof of work eligibility)
• Photograph for identification purposes
• Proof that you are legally entitled to work within the UK
• Information that we may obtain from public sources including social networking sites such as Facebook™/Twitter™ accounts
• Other personal details included in a resume or cover letter or that you otherwise voluntarily provide to us
Our collection and use of some personal data is mandatory in order for us to administer our relationship with you (for example your National Insurance number and income tax liability). Failure to provide or allow us to process mandatory personal data may affect our ability to continue with your employment or worker or contractor relationship.

Use of Personal Data
We only process your personal data where law permits or requires it, including where the processing is necessary for your employment, for our legitimate interests or the legitimate interests of third parties. We may process your personal data for the following legitimate business purposes and for the purposes of performing the employment contract with you:
• Employee administration (including payroll and benefits administration)
• Business management and planning
• Processing employee work-related claims (for example, insurance claims)
• Accounting and auditing
• Conducting performance reviews and determining performance requirements
• Assessing qualifications for a particular job or task
• Gathering evidence for disciplinary action or termination
• Complying with applicable law
• Education, training, and development requirements
• Health administration services
• Complying with health and safety obligations
We will only process your personal data for the purposes we collected it for or for compatible purposes. For example, this may include for outward facing personnel, providing third parties who may need your work contact details (such as suppliers and customers) with your name, job title, work telephone numbers, work email address and times of availability. If we need to process your personal data for an incompatible purpose, we will seek your consent.

Collection and Use of Special Categories of Personal Data
The following special categories of personal data are considered sensitive under the laws of your jurisdiction and may receive special protection:
• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership
• Data concerning health
• Data concerning sexual orientation
• Data relating to criminal convictions and offences
We may use special categories of information such as race/ethnicity/sexual orientation in an anonymised form for statistical purposes or circumstances such as responding to government surveys or tendering for contracts that require knowledge of our “make up”. This form of information would not be “personal data” as you cannot be identified from the statistics.
Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

Data Sharing
We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering your relationship with us, including third-party service providers who provide services to us or on our behalf. Third-party service providers may include, but not be limited to, payroll processors, benefits administration providers, and data storage or hosting providers.
We require our third-party service providers to implement appropriate security measures to protect your personal data consistent with our policies and applicable law. We only permit them to process your personal data for specified purposes in accordance with our instructions or as required by law.
We may also disclose your personal data for a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonymise the data where possible.

Data Security
We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes.

Rights of Access, Correction, Erasure, and Objection
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your employment or working relationship with us. By law you may have the right to request access to, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances. You may also have the right to request that we transfer your personal data to another party. If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact our finance department in writing.
Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Withdraw Consent
Where you have provided your consent to the collection, processing, or transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances (some personal data we are required to retain by law). To withdraw your consent, if applicable, contact our finance department in writing.
We have appointed our financial controller to oversee compliance with this Privacy Policy. If you have any questions about this Privacy Policy or how we handle your personal data, or would like to request access to your personal data, please contact our finance department. If you are unsatisfied with our response to any issues that you raise with us, you may have the right to make a complaint with the Information Commissioner.

Changes to This Privacy Notice
Publication Date: 25th May 2018
We may update this Policy at any time but if we do so, we will notify you as soon as reasonably practical.