HR Data Protection Policy

1. PRIVACY STATEMENT
   • Imagine Cruising Limited (“we”/”us”/” our” etc) is committed to protecting the privacy of your personal data collected in the course of your work with us. This HR Data Protection Policy does not form part of your contract with us and we may amend it at any time.
   • We are a retailer of goods and services based at Portland House, Bincknoll Lane, Interface Business Park, Royal Wootton Bassett, Wiltshire, SN4 8SY.
   • Our email address is HumanResources@imaginecruising.co.uk
   • We will always comply with relevant data protection legislation (including the Data Protection Act 1998 (“DPA”) and General Data Protection Regulation (“GDPR”) as applicable) when dealing with your personal data. Further details on the DPA and GDPR can be found at the Information Commissioner’s Office website (www.ico.gov.uk).  For the purposes of data protection legislation, we will be the “controller” or “data controller” of all personal data held in respect of this Policy.
2. DATA PROCESSING
   • In this Policy we use certain terms from the relevant data protection legislation;
     • “data subject” i.e. anyone who can be identified from personal data;
     • “controller/data controller” i.e. a business which holds personal data and decides how it should be processed;
     • “processor/data processor” i.e. a business which holds personal data on behalf of a controller and processes it in accordance with the controller’s instructions;
     • “personal data” i.e. recorded information we hold about you from which you can be identified. It may include contact details, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you;
     • “special categories of personal data” i.e. relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health, sex life or sexual orientation;
     • “processing” i.e. doing anything with personal data including collecting, using, storing, accessing, disclosing and destroying it.
   • We will process your personal data in accordance with the following principles:
     • all personal data must be processed lawfully, fairly and in a transparent manner;
     • all personal data must be collected for one or more specified, explicit and legitimate purposes and not processed in a manner incompatible with those purposes;
     • all personal data shall be restricted to what is adequate, relevant and limited for those purposes;
     • all personal data shall be kept accurate and up to date (and reasonable steps must be taken to erase or rectify inaccurate personal data);
     • all personal data must be kept for no longer than is necessary for those purposes;
     • all personal data must be protected by appropriate technical and organisational security measures to prevent unauthorised or unlawful processing and accidental loss, destruction or damage.

3. YOUR PERSONAL DATA
   • We may process your personal data where necessary for legal, personnel, administrative and management purposes in order to:
     • deal with applications for positions with us (even if unsuccessful);
     • deal with contracts with employees;
     • deal with contracts with agency workers, contractors, consultants etc;
     • deal with arrangements with volunteers, interns and those on work experience;
     • perform (or take preliminary steps prior to) any contract to which a data subject is a party;
     • exercise our legitimate business interests;
     • comply with our legal obligations;
     • carry out other functions with your specific consent; or
     • as otherwise permitted by relevant data protection legislation.
   • In addition, we will only process special categories of personal data where:
     • we have your explicit consent;
     • it is necessary and permitted in relation to your employment (or respective situation if not employed) e.g. in order to monitor sick leave and take decisions as to your fitness for work, or to monitor compliance with equal opportunities and other legislation;
     • you have made the personal data in question manifestly public;
     • it is necessary in connection with legal claims or court action; or
     • as otherwise permitted by relevant data protection legislation.
   • We will only process your personal data to the extent that it is necessary for the purposes specified in this Policy (or otherwise notified to you) and we will keep the personal data we store about you accurate and up to date. Where it is inaccurate or out of date, it will be destroyed – please let us know if your personal details change or if you become aware of any inaccuracies in the personal data we hold about you.
   • We will not keep your personal data for longer than is necessary for the purposes specified in this Policy (or otherwise notified to you). Where it is no longer required, it will be pseudonymised, anonymised, destroyed or erased as appropriate. [For guidance on how long certain data is likely to be kept before being destroyed, contact the Human Resource Department at Imagine Cruising.]
   • We will never sell your personal data or make it available to any third parties without your prior consent (which you are free to withhold) except where:
     • we use a processor, in which case we will ensure that the processor complies with this Policy and all relevant data protection legislation;
     • we are required to do so by law;
     • we sell any part of our business or assets (in which case we may disclose your personal data confidentially to the prospective buyer as appropriate in accordance with our legitimate interests).
   • We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction. We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
   • We reserve the right to amend this Policy from time to time without prior notice. You are advised to check the Site regularly for any amendments (but NB amendments will not be made retrospectively).
   • We will not transfer your personal data outside the EEA/EU without your consent. Consent will be obtained at the commencement of your employment. For existing employees this will be obtained through the Employee Privacy Notice consent process.
4. YOUR RIGHTS
   • You have the following rights under the in respect of your personal data held by us. Please send all requests in respect of these rights to our Human Resources Department:
     • to access your personal data;
     • to be provided with information about how your personal data is processed (this information is set out in this Policy);
     • to have your personal data corrected where necessary (please contact us promptly should you become aware of any incorrect or out-of-date information);
     • to have your personal data erased in certain circumstances (please refer to the appropriate data protection legislation or consult the ICO for details);
     • to object to or restrict how your personal data is processed;
     • to have your personal data transferred to yourself or to another business.
   • If you consider that we have not complied with this Policy or the relevant data protection legislation in respect of your personal data or someone else’s, you should raise the matter with your line manager or our Human Resources Department at HumanResources@imaginecruising.co.uk Any such breach will be taken seriously, will be dealt with in accordance with the relevant data protection legislation and may result in disciplinary action.
   • You have the right to take any complaints about how we process your personal data to the Information Commissioner:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

https://ico.org.uk/make-a-complaint/

0303 123 1113.

For more details, please consult the relevant data protection legislation or address any questions, comments and requests regarding our data processing practices to our Human Resources Department.