Privacy Policy

We take the security of your personal data extremely seriously. We believe that our data protection policies are comprehensive and in parts go above and beyond our legal duties under the regulations.

Under the GDPR the data protection principles are considered to be;
Data that is processed lawfully, fairly, and in a transparent manner in relation to the data subject.

Data that is collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

Data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

Data that is accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.

Data that is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

Data that is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

Under GDPR we confirm that we are Data Collectors and Processors.

We trust that the information contained within this policy will put you in a position whereby you can make an informed decision to give your consent to collect and or process your data referred to as ‘Opting-in’

1, Introduction to our Privacy Policy under the General Data Protection Regulations (GDPR)

It’s not easy to convey such a policy to you without referring to and using many legal terms and references. That said, we believe in identifying the spirit in which this policy legislation is intended, and we would summarise this as follows;

1.1, We will explain to you why we collect your data,

1.2, What we do with it,

1.3, Who we may share it with,

1.4, How we try and keep it safe,

1.5, What rights you have to see and change anything we keep about you.

1.6, What prompt and concise actions we will take should the data we store and or process is ever obtained from us unlawfully, exposed to unnecessary risk or threatened in any way.

Once we have explained the above we would like to think that you have all the information you need in order to make an informed decision whether to consent to us collecting and processing your data known as ‘OPTING IN’

This Policy sets out the duties of us, Rhythm Room Ltd, 10589614 (“the Company”) regarding data protection and the rights of individuals, organisations, companies (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The procedures and principles set out herein will be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

2, Our lawful and legitimate reasons for collecting your data under GDPR

The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject.

The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

The data subject has given consent to the processing of their personal data for one or more specific purposes;

2.1, The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

2.2, The processing is necessary for compliance with a legal obligation to which the data controller is subject;

2.3, The processing is necessary to protect the vital interests of the data subject or of another natural person;

2.4, The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested the data controller; or

The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

If the personal data in question is “special category data” (also known as “sensitive personal data”) for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

2.5, The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);

2.6, The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

2.7, The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

2.8, The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;

2.9, The processing relates to personal data which is clearly made public by the data subject;

2.10, The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

2.11, The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;

2.12, The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;

2.13, The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or

2.14, The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

3, Personal Data collected, stored and Processed

The following personal data is collected, held, and processed by the Company:

Reference: PD001

Data Type: Essential contact information

Purpose of Data: In the course of supplying a service to you or fulfilling a contract

Reference: SD001

Data Type: Personal ID/Photo documentation

Purpose of Data: Employee/Employment related matters

Reference: HRD001

Data Type: Address, Bank Details

Purpose of Data: Employee/Employment related matters

4, Special Category Data (also known as “sensitive personal data) collected and processed

Reference: n/a

Data Type: n/a

Purpose of Data: None Currently held

5, Our policy regarding collecting and processing children’s data

We have Privacy Policies in place with Children in mind such as enhanced Data Protection Impact Assessment (DPIA’s) We cannot stop children providing data to us but where relevant we make sure that the child understands what they are consenting to, and we do not exploit any imbalance in power in the relationship between us.

The following are some guidance pointers, as directed by the Information Commissioners Office, that we have adopted in our dealings with children;

5.1, Children have the same rights as adults over their personal data. These include the rights to access their personal data; request rectification; object to processing and have their personal data erased.

5.2, Children merit specific protection when you use their personal data for marketing purposes or creating personality or user profiles.

5.3, We must have a lawful basis for processing a child’s personal data. Consent is one possible lawful basis for processing, but it is not the only option. Sometimes using an alternative basis is more appropriate and provides better protection for the child.

5.4, If we are relying on consent as our lawful basis for processing personal data, when offering an online or direct service directly to a child, only children aged 13 or over are able provide their own consent. (This is the age proposed in the Data Protection Bill and is subject to Parliamentary approval).

5.5, For children under this age we need to get consent from whoever holds parental responsibility for the child - unless the online or direct service we offer is a preventive or counselling service.

As a matter of good practice, we use DPIA’s to help us assess and mitigate the risks to children.

If our processing is likely to result in a high risk to the rights and freedom of children then we always do a DPIA.

6, The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

6.1, The right to be informed (Part 7).

6.2, The right of access (Part 19);

6.3, The right to rectification (Part 21);

6.4, The right to erasure (also known as the ‘right to be forgotten’) (Part 21);

6.5, The right to restrict processing (Part 21);

6.6, The right to data portability (Part 22);

6.7, The right to object (Part 20); and

Rights with respect to automated decision-making and profiling (Part 20).

7, Keeping Data Subjects Informed

Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and

Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

7.1, if the personal data is used to communicate with the data subject, when the first communication is made; or

7.2, if the personal data is to be transferred to another party, before that transfer is made; or

7.3, as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

The following information shall be provided:

7.4, Details of the Company including, but not limited to, the identity of its Data Protection Officer;

7.5, The purpose(s) for which the personal data is being collected and will be processed (as detailed in sections 3, 4, 10 and 16 of this Policy) and the legal basis justifying that collection and processing;

7.6, Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

7.7, Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

7.8, Where the personal data is to be transferred to one or more third parties, details of those parties;

Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 17 of this Policy for further details);

Details of data retention;

7.9, Details of the data subject’s rights under the GDPR;

7.10, Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);

7.11, Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;

and Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

8, Accuracy of data and the updating of it

The Company will only collect, and process personal data shown in sections 3 and 4 above for the extent necessary to perform the task in which it was collected for or until the data subject is notified. The data will be monitored by us on a regular basis but no later than every 3 Months from the date it was first collected.

9, Impact assessments we undertake

The Company shall carry out Data Protection Impact Assessments (DPIA’s) which will be overseen by our Data Protection Officer.

We will consider risks posed to data subjects resulting in collection and processing of data both from within our company and to the company.

Various manual and or electronic storage and protection systems and facilities are at our disposal and we will make decision on the suitability of which systems and facilities to use.

Our decisions will be based on some key factors which include but are not limited to;

9.1, Who within our company has access to your data.

9.2, Will your data be processed by a third party (at our discretion)

9.3, What volume of data we hold.

9.4, What is the sensitivity and risk involved relating to the data we hold.

At all times we will act with the necessity and proportionality of the data processing with respect to the purposes for which it is being processed.

10, Our Data Protection Officer

Our nominated Data Protection Officer (DPO) is Kevin Hickman who can be contacted by email, kev@rhythmroom.co.uk or by writing to 247 Queensway, Bletchley MK2 2EH. Systems will be in place that in the event that our Data Protection Officer is unavailable your enquiries will be directed to suitably qualified individuals within our organisation. Our DPO will be responsible for overseeing the collection and processing of data including relevant Third Party processors.

11, Third Party Data Processing

We may as part of our collection, storage and processing of data, interface with other individuals, organisations or businesses (referred to as Third Party Processors) in order to perform the task in which it was collected for.

Third Party processors will be expected to fulfil the criteria set out to them by our DPO. The Third Party’s own GDPR policies will be regularly monitored in order that they meet the ongoing legislation.

If you wish to be provided with details of all of the Third Party processors we have used or are likely to use that have or are likely to process your data then please contact our DPO who will provide that information to you without any charges to you whatsoever.

Some of our regularly used Third Party processors include the following;

Organisation: Microsoft

Data Type: Administration & Email