Privacy Policy

Anna Norton trading as Virtual HR, referred to as ‘VHR, ‘we’ or ‘our’, is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection (Jersey) Law 2018 (DPJL).

VHR is a "Data Controller". This means that we are responsible for deciding how we hold and use personal information.

We are required under data protection regulations to notify you of the information contained in this Privacy Notice.

VHR is a registered entity in France with the Business Registration Number No. 884 651 985 00019.

We will comply with GDPR and DPJL. They say that the personal information we hold about you must be:-

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

We will also only transfer your information when it is safe to do so, when it is necessary to do so and your information is protected in the same way that we protect it.

VHR is accountable to you and the Authorities to not only show compliance with the data protection laws but also to demonstrate how we are compliant.

The Data Protection Manager (“DPM”)

We have appointed a DPM to oversee compliance with this Privacy Notice.

If you have any questions about this Privacy Notice or, how we handle your personal information, please contact the DPM at DPM-VHR@Propelfwd.com

You have the right to make a complaint at any time to the Commission Nationale de l’Informatique et des Libertes (CNIL) or the Jersey Office of the Information Commissioner (JOIC), the supervisory authorities in France and Jersey.

Contact details for these is outlined at the bottom of this Privacy Notice.

Data Protection Representative

In compliance with Article 4(3) of the Data Protection (Jersey) Law 2018 VHR has appointed Propelfwd to be our Data Protection Representatives in Jersey. As VHR is established in France and has no establishment in Jersey, Propelfwd will be the main contact point for Data Subjects whose data VHR processes.

How Is Your Personal Information Collected?

We collect personal information about our you when you contact us, engage us to advise on HR related matters, engage us to be your outsourced HR managers or contact us for any other specific matter or service.

What information do we collect about you?
  • Name
  • Title
  • Address
  • Data of Birth
  • Entitlement status
  • Telephone number
  • Occupation
  • Email address
  • Signature
  • Bank details

Where necessary, we may also collect the following information:

  • Previous employment history.
  • References from previous employers.
  • Criminal convictions (other than those considered Spent).
  • Identification documents.
  • Relevant medical history
  • Experience and skill required for employment
What Special Category Data we collect about you?

When we collect what is called Special Category data, we will always have either a clear legal basis to process this or your explicit consent. If we rely on your explicit consent, you can withdraw this at any time by contacting our DPM at DPM-VHR@Propelfwd.com

Special Category data is any information relating to your health, gender, race, sexual orientation, sex life, genetic or biometric data etc.

An example of this processing would be, when you engage us advise or be an outsourced HR Manager we will need information relating to a specific disability an employee may have so we can assist them in the performance of their employment.

How We Will Use Information About You?

We will only use your personal information when the law allows us to, this is called a legal basis (highlighted in bold) for processing your information (data).

Most commonly, we will use your personal information in the following circumstances:

  1. Where you have entered into a contract with us to provide you with a service. This would be when engage us for a service and sign a contract of agreement.
  2. Where we need to comply with a legal obligation. This would be when we have to comply with a part of the Employment Law.
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. An example of this is when we send you information or an update on employment policies or internal matters relating to employment.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where you have given, you consent provide information or for us to contact you for a specific purpose.
  2. In an emergency and it is in your vital interest that we share your information, when we have it recorded.
Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Data Sharing

We may on occasions pass your Personal Information to organisation outside of VHR exclusively to process on our behalf, these organisations are called Data Processors.

We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.

We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or the United Kingdom.

It may also be processed by companies operating outside the EEA / UK who work for us or for one of our service providers.

If we do this, we ensure that your privacy rights are respected in line with this Policy and the same protection is given to your personal information as laid down by the DPJL and GDPR.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way,. In addition, we limit access to your personal information to those Staff, Agents, Contractors and other third parties on a need to know basis.

They will only process your personal information on our strict instructions and they are subject to a duty of confidentiality.

Details of these measures may be obtained from our Data Protection Manager (DPM).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request our Data Retention Schedule from our DPM if required.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of Access, Correction, Erasure, and Restriction

It is important that the personal information we hold about you is accurate and current.

Please keep us informed if your personal information changes during your relationship with us.

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing or request that we transfer a copy of your personal information to another party, please contact our DPM at DPM-VHR@Propelfwd.com.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

How to request your information and what we may need from you

Please use the Data Subject Access request form, available on our Cookie Banner. If you have any questions about this process or any of your rights, please contact our DPM at DPM-VHR@Propelfwd.com

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

We will respond to your request within 4 weeks after and upon satisfactory verification of your identity.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, please contact our DPM at DPM-VHR@Propelfwd.com.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.

We may also notify you in other ways from time to time about the processing of your personal information or requesting you to confirm the accuracy of the information we hold on you.

Complaints

We would like the chance to resolve any complaints you have about the way we process your information; however, you do have the right to complain to the Commission Nationale de l’Informatique et des Libertes (CNIL) or the Jersey Office of the Information Commissioner (JOIC) about how we have used your personal data.

The details for each of these contacts are:

Virtual HR – Data Protection Manager
6 Vine Street, Second Floor, St Helier, Jersey JE2 4WB
Telephone +44 (0) 1534 735330 or Email: DPM-VHR@Propelfwd.com.

Commission Nationale de l’Informatique et des Libertes (CNIL)
3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France
Telephone +33 (0) 1.53.73.22.22

Jersey Office of the Information Commissioner
2nd Floor, 5 Castle St, St Helier, Jersey JE2 3BT
Telephone +44 (0) 1534 716530 or Email: enquiries@dataci.org.