Privacy Policy

The W12 Group of companies understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our employees, clients and suppliers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. 

1. Information About Us 

W12 Group Limited (company no. 09680905) includes: 

• W12 Construction Limited (company no. 08922731)
• W12 Maintenance Limited (company no. 10136775)
• W12 Waste Limited (company no. 10139206)
• W12 Catering Limited (company no. 10577991) 

All companies are registered in England with registered offices at 4 Capricorn Centre, Cranes Farm Road, Basildon, Essex SS14 3JJ 

Trading address and contact details for all companies is W12 House, 2 Chipstead Lane, Lower Kingswood, Tadworth, Surrey KT20 6RE, tel 020 7939 1913, email info@w12group.co.uk 

Your contact for all data queries is the Data Officer named in Section 16. 

Some of our companies are registered as Data Controllers under the Data Protection Act 2018, as follows: 

• W12 Maintenance Limited (reference A8335840)
• W12 Catering Limited (reference A8336143) 

2. What Does This Notice Cover? 

This Privacy Notice explains how we use your personal data; how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. 

3. What Is Personal Data? 

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the ‘GDPR’) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. 

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. 

The personal data that we use is set out in section 5 below. 

4. What Are Your Rights? 

Under the GDPR, you have the following rights, which we always work to uphold: 

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in section 16.
2. The right to access the personal data we hold about you. Section 14 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
4. The right to be forgotten, ie, the right to ask us to delete or otherwise dispose of any of your personal data that we have.
5. The right to restrict (ie, prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to reuse with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way. Section 7 explains more about how we use your personal data. 

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Section 16.

Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO) or your local Citizen’s Advice Bureau (CAB). 

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the ICO. 

5. What Personal Data Do We Collect? 

We may collect some or all of the following personal data (this may vary according to your relationship with us): 

• Name
• Address
• Email address
• Telephone number/s
• Job title
• Business name, address & contact details
• Type of business
• Information about your preferences and interests
• Business information (eg, VAT registration, company number, UTR number, size of company, number of employees, number of properties)
• Property information (eg, location, type of property, ownership status, access information)
• Social media contact information
• Payment information
• National insurance number
• UTR number
• Date of birth
• Next of kin / emergency contact
• Passport
• Driving Licence
• Qualifications and training information
• Salary/wages information
• Banking information
• Employment history information
• Details of terms and conditions of pay, hours of work, holiday entitlement and other benefits
• Accident information
• Health and self-declared medical information
• Attendance information
• Performance information
• Equal opportunities information

6. How Do We Collect Your Personal Data? 

We collect personal data that is given to us in person and electronically. Your personal data may be obtained by mutual communication from the following examples: 

• Email
• Telephone
• Post
• Social media
• Website cookies
• Website contact forms
• Information request forms
• Marketing opt-ins

We do not buy personal data from third party companies although we may be introduced to you by a third party by mutual consent. 

7. How Do We Use Your Personal Data? 

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes: 

• Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email and post that you have requested or opted-in to.
• Employing you. Your personal details are necessary for your employment contract and some data is legally required.
• Allowing you to supply your services to us. Your personal details are necessary for us to enter into a contract with you and some data is legally required.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message, social media, post, with information, news and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. 

8. What Happens If You Do Not Supply Your Personal Data? 

If your personal data is necessary and you fail to supply the information we need, we may not be able to enter into a contract with you, for example an employment contract, a subcontract, a sales contract. 

Without relevant personal data we may not be able to engage in a relationship with you, for example, a pre-sales relationship, estimating or quoting for business, considering contracts, conducting employment interviews, etc. 

9. What Happens If There Is A Change In Purpose Of Information? 

Your personal data will only be stored for the original purpose for which it was gathered. However, if there is a change in purpose, for example, you change from being a subcontractor to being an employee, we will seek your permission to retain and update the data we already hold. Any change of purpose for holding data will be relevant. 

10. What If My Personal Data Is Sensitive Or Confidential?

We will treat your personal data with due care and respect.  All personal data will be stored securely with access restricted to relevant personnel. 

Computer systems will be protected by passwords, encryption and appropriate protective software. Cloud-based software holding personal data will only be used if the supplying company confirms their compliance with GDPR. 

We strive to be a paperless office but where we deem necessary to keep hard copies, they will be kept in locked offices or cabinets in locked offices. Any hard copies no longer required including printed drafts of documents will be destroyed securely via a bona fide confidential shredding service or incineration on our premises. 

11. How Long Will We Keep Your Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason/s for which it was first collected. Your personal data will therefore be kept for the following periods (or where there is no fixed period, the following factors will be used to determine how long it is kept): 

• Business purposes: Your personal data will be held for the duration of the contract. To maintain our business accounts and records we are under a legal obligation to retain some of your personal data for a minimum of 6 years.
• Employment purposes: Your personal data will be held for the duration of the contract. To maintain our business accounts and records we are under a legal obligation to retain some of your personal data for a minimum of 6 years.

12. How and Where Do We Store or Transfer Your Personal Data? 

We will only store or transfer your personal data within the European Economic Area (EEA) or countries or companies that have demonstrated their compliance with GDPR, such as the companies listed below. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law. 

We currently store data on the following platforms ultimately based outside the EEA (whose servers are likely to be based in the United States of America): 

• Microsoft - https://www.microsoft.com/en-us/trustCenter/privacy/gdpr
• Google - https://cloud.google.com/security/compliance/gdpr/
• Xero - https://www.xero.com/uk/campaigns/xero-and-gdpr/
• Dropbox - https://www.dropbox.com/en_GB/security/GDPR

13. Do We Share Your Personal Data? 

We may sometimes contract with third parties to supply services and/or products to you on your behalf. These may include subcontractors, suppliers, business partners, business services, payment processing and marketing. In some cases those third parties may require access to some or all of your personal data that we hold.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely and in accordance with your rights, our obligations and the third party’s obligations under the law, as described in Section 12 above.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. 

14. How Do You Access Your Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a ‘subject access request’. All subject access requests should be made in writing and sent to the email or postal address shown in Section 16.

There is not normally a charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 30 days. Normally we aim to provide a complete response including a copy of your personal data within that time. In some cases however, particularly if your request is more complex, more time may be required up to a maximum of 3 months from the date we receive your request. You will be kept fully informed of our progress. 

15. How Do We Remove Your Personal Data?

 Electronically held data will be deleted. Printed matter will be securely destroyed via a bona fide confidential shredding service or incinerated on our premises. 

16. Who To Contact? 

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: 

• Susannah Brady, Group Director
• Email info@w12group.co.uk
• Telephone 020 7939 1913
• Postal address W12 House, 2 Chipstead Lane, Lower Kingswood, Tadworth, Surrey KT20 6RE

17. Changes To This Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we expand/reduce our group of companies, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website www.w12.group

This Privacy Notice was published on 24.05.2018