Privacy Notice

We have updated this privacy notice following the introduction of new legislation earlier this year (GDPR) and take seriously our obligation to handle any personal data in accordance with those regulations.

  1. Who we are?
  2. Whose data do we process?
    • As a Data Controller
    • As a Data Processor
  3. Where we might capture Personal Data?
  4. Why do we process Personal Data?
  5. What data do we process>
    • Running our Company
    • Employee and recruitment data
    • CCTV
    • Marketing information
      • Cookies
      • Google Analytics
    • To fulfil our legal requirements
    • Special categories of data
  6. Where do we process the data?
  7. How long do we keep the data for?
  8. Who will we share data with?
  9. Personal Data processed by 3rd parties
    • Credit Checks and Security Vetting
  10. Security
  11. Changes to Business Organisation
  12. Access to personal information
  13. Complaints or queries
  14. Your rights
    • Right to erasure
  15. Disclosure of personal information
  16. Changes to this Privacy Notice

1. Who we are?

We are Capita Property and Infrastructure and GL Hearn Limited and we provide Real Estate and Infrastructure consultancy services to business clients.

These services include but not limited to;

  • Property Management (housing, residential and commercial)
  • Transport Infrastructure & design services
  • Specialist Infrastructure solutions (defence sector)
  • Health and Safety services
  • Property consulting / Professional Services

We can be contacted in connection with this notice at CPI.Infosec@capita.co.uk or privacy@capita.co.uk 

Our websites are www.capitaproperty.co.uk/ and www.glhearn.com

 

Registered address

Real Estate and Infrastructure: Capita plc, 30 Berners Street, London, W1 3LR

GL Hearn: Capita Plc, 30 Berners Street, London W1T 3LR.

 

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed.

Any requests for this should be sent to our registered address or email address above.  

2. Whose data do we process

As a Data Controller

A data controller defines the manner and purpose of processing personal data.  As such, we process personal data of the following groups of people;

  • Employees, ex-employees and potential employees
  • Visitors to our places of work
  • Individuals in our customers’ organisations
  • Individuals in our suppliers’ organisations
  • Visitors to and users of our websites
  • Specialists with whom we engage to deliver projects
  • Users of the systems that we provide
  • Callers to our telephone systems
  • People who give us business cards
  • People included on purchased marketing lists or provided to us by our business partners
  • Customers - When we are the Data Controller, we process information obtained directly from our customers such as name, address, billing information, and some employee contact information. We may also collect other information about the customer and some employees, for example through our web sites and service interactions, as part of that data.

As a Data Processor

A data processor is the natural or legal person, agency or other body which processes personal data on behalf of a data controller

  • Capita Property and Infrastructure and GL Hearn Limited provide services to clients which include the processing of personal data relating to the client, the client’s staff or the client’s customers. In these cases, the client is the Data Controller and we are the Data Processor. As Data Processor, we process the personal data on behalf of the Data Controller, under their instructions, as agreed in our contracts.
  • We may also process personal data as a sub-processor. This means that we have been engaged by the Data Processor to process personal data under their instructions as part of the role of delivering services to the Data Processor, as agreed in our contract.
  • Where we are a Data Processor, we process personal information in accordance with the instructions that we have in the contract or service order or in accordance with our own internal policies and procedures updated in accordance with GDPR. Where we provide a service, the personal data is classified and handled in accordance with the terms of the contract or the order for those services.

3. Where we might capture Personal Data?

  • From our websites - Individuals can contact us using functions provided on our website and we capture personal information (for example email addresses, IP addresses, names, address, job title) about that communication.
  • From our sales order processing systems.
  • From our customers - Customers may provide us with lists of authorised business contacts for the functions we are contracted to provide.
  • From third party marketing companies or business partners (i.e. purchased marketing lists)
  • From suppliers, partners and contractors where it is necessary to provide their contracted services - Names, contact details and previous experience of employees and specialists involved in delivering the services.
  • From events, conferences and exhibitions we attend, either from personal contact or from the organisers and promoters (e.g. business cards and attendee lists).
  • From details provided to us by individuals.
  • From CCTV.
  • From potential employees, including contractors, during the recruiting process.
  • From CVs when people are referred to us by colleagues or other contacts.
  • When people log in as “Guest” to our WIFI networks.
  • When people park in our carparks.
  • When people sign in to our visitor’s books.
  • For secure sites, when people provide further details to enable us to identify them.
  • From our staff, for employment reasons.
  • From our staff, for security purposes.
  • Investigations following an incident e.g. security and or health and safety.
  • Lists of people who are or have attended networking events, usually from organiser / promoter.  

4. Why do we process Personal Data?

We process Personal Data where it is necessary for the following purposes;

  • To assist in the running of the company; including, but not limited to invoicing, billing, arranging visits and internal record keeping.
  • For employment and recruitment purposes, including identifying suitable specialist’s contractors for certain project.
  • To fulfil our contractual obligations, provide goods and services to our customers and answer queries.
  • For security and prevention of crime (CCTV).
  • For Safety, Health and Environment incident monitoring and prevention.
  • To market ourselves to other businesses using named individuals within those businesses, and to reply to individuals who have contacted us.
    • to deal with requests and queries;
    • to forward job applications to the appropriate department;
    • to carry out marketing activities, where you have agreed to it.
    • to carry out any business processing in accordance with this privacy notice.
  • To improve our products and services; - Using feedback provided by individuals - For training and quality purposes (voice recording) - Legal and regulatory reasons e.g. HMRC and regulatory reporting.

5. What data do we process?

Running our Company

We process the necessary information in our legitimate interests;

  • To fulfil our contracted relationships, provide goods and services to our customers, answer queries, obtain payment (invoicing, billing process), arrange visits, or during internal record keeping - Business contact details
  • To improve our products / services - Using feedback provided by individuals - For training and quality purposes (voice recording)
  • To carry out vetting and/or credit checking of potential employees, customers and suppliers (such as contractors)
  • To satisfy our clients security requirements we provide a vetting service for HMG BPSS which includes the following fields:
    • Name, address and contact details
    • Residence and employment history
    • Nationality
    • Criminal history

Employee and recruitment data

For information regarding the processing of employee data, please contact privacy@capita.com.

Current employees should refer to the Employee Handbook. 

CCTV

We may use CCTV to record images at any of our locations at any time. We may also use monitored CCTV systems in some of our locations. These images may be of any person present at our locations.   

The purpose of this CCTV is for the safety of the public and staff at these locations, and to prevent and detect crime. In locations that have CCTV there are signs displayed notifying you that CCTV is in operation. 

Marketing Information

  • We use marketing information in our legitimate interests to reach other businesses and where we have consent to contact private individuals.
  • We use information known to us as business contact details (name, role, telephone number, email and physical address) to provide details of goods and services that we believe may be of interest to you.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information.  This information is used to track visitor use of the website and to compile statistical reports on website activity.

For further information visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

You can find out more about our use of cookies on our .

Google Analytics

We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on.

This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.

We have also implemented Google Analytics Demographics and Interest Reporting. This is used to gain an insight into the age, gender and interests of our users to help us make decisions on how to improve the website in the future. Users can opt out of this reporting by visiting Google Ads Settings.

You can find out more about Google’s position on privacy about its analytics service at https://support.google.com/analytics/answer/6004245?hl=en-GB

Visitors may choose to opt-out of Google Analytics tracking with Google Analytics opt-out browser add-on.

To fulfil our legal requirements

  • Safety, Health and Environment incident monitoring and prevention
    • We keep details of Safety, Health and Environment incidents, near misses and assessments to keep our staff and members of the public safe, and in accordance with SHE legislation.
    • We may use CCTV images for the purposes of SHE incident monitoring and prevention.
  • Where we believe it is necessary to comply with any law enforcement agency, court, regulator or official registrar (such as the Financial Conduct Authority or Companies House), or government authority, we may process your Personal Data to meet our obligation. Examples of this are to fulfil our obligation with regards to tax regulations, or to equal opportunity monitoring.  

Special categories of data

  • We may process certain special categories of Personal Data (which are defined as Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation).
  • We may also process Personal Data relating to criminal convictions and offences, which are not special categories of Personal Data but are subject to special rules under the GDPR.
  • In line with our obligations as an employer, we will use your particularly sensitive personal information in relation to;
    • leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
    • your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
    • your race or national or ethnic origin, religious, philosophical or moral beliefs, or your gender, to ensure meaningful equal opportunity monitoring and reporting.
    • any criminal convictions, police cautions, court appearances (including in respect of country court judgements), civil disputes, bankruptcy proceedings and individual voluntary arrangements etc. in deciding if a candidate or employee is appropriate for a role.

6. Where do we process the data?

  • We process Personal Data in our offices and data centres in the UK.
  • We also process some Personal Data in our offices in the Republic of Ireland, Poland and in India.
  • In accordance with good practice, and because it is outside the EEA, all engagements with India are underpinned by suitable Inter-company agreements.

7. How long do we keep the data for?

We keep Personal Data for no longer than it is needed, and in accordance with our Data Retention Policy.

Examples of this might be:

  • for as long as your account is active
  • as needed to provide you with products or services
  • as needed for the purposes outlined in this Policy or at the time of collection
  • as necessary to comply with our legal obligations (e.g. to honour opt-outs)
  • resolve disputes, and enforce our agreements
  • or to the extent permitted or required by law. At the end of the retention period, we will delete your Personal Data in a manner designed to ensure that it cannot be reconstructed or read.

However, we may need to retain it for longer if we cannot delete it for one or more of the following reasons:

  • to respond to any questions, complaints or legal claim that may arise;
  • to show whether we treated you fairly;
  • for legal, regulatory or technical reasons.

If we do, we will make sure that your privacy is protected and only use it for those purposes.

8. Who will we share data with?

In the running of our business, we sometimes work closely with other organisations. Your personal information may be passed to one of these organisations when required to perform the service. However, Capita Property and Infrastructure and GL Hearn Limited will still be responsible for your information, its security and what happens to it. 

In addition to this, we may be required by law to share your information with some of these organisations. 

Typically, depending on the circumstances, we share information with the following types of organisations;

  • Contracted third parties where the information shared is necessary to provide the service
  • Law enforcement agencies such as the Police, and Fire and Rescue Service
  • Other government / regulatory agencies as required by law
  • Our external auditors
  • Customers, where we are providing people to work with and for them (e.g. identification information, CV info, qualifications, certifications and security vetting)
  • Other Capita Group companies. We share Personal Data when it is necessary among our group companies. All group companies are required to comply with equivalent privacy notice obligations.
  • Our Vetting and credit checking partners.

Where we do share your information, we will take steps to ensure that those it is shared with keep your information secure, and that they also comply with legislation. The work will be underpinned by appropriate commercial agreements.

9. Personal Data processed by 3rd parties

Where we have contracted Personal Data processing to a third party, we have contracts in place with our Data Processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Credit Checks and Security Vetting 

We may enter in to arrangements with other companies to provide credit checks and security vetting, where although we are commissioning a service, they will also act as Data Controller for the data that you provide and will determine the purpose and manner of processing. Where this happens, you will be informed when you provide the data.   

10. Security

We are committed to the security of all Personal Data and have various policies and tools in place to ensure the physical, administrative and technical security of all data in our care, which includes Personal Data. We use security practices and operating procedures that are compliant with standard industry practices or other practices as defined in the relevant service description or contract document (as applicable). 

Where we are a processor, practices include having technical and organisational measures to prevent unauthorised or unlawful processing or accidental loss, destruction or damage of personal data based on the nature of the personal data being protected.  We also ensure the reliability of any employees who access personal data through regular and mandated training policies.

Where relevant and applicable we obtain external certifications such as ISO 27001, ISO 22301, PCI DSS, and Cyber Essentials plus.  

We also require that our third-party partners and suppliers protect any Personal Data that they process from unauthorised use, alteration, loss and disclosure. 

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

11. Changes to Business Organisation

We may from time to time, expand or reduce our business and this may involve a reorganisation of our business operations, including buying new businesses or selling or merging existing businesses. This may involve us disclosing Personal Data to prospective or actual purchasers of parts of our business or receiving Personal Data from potential sellers. We will obtain appropriate confidentiality protection for Personal Data disclosed in these types of transactions.

Relevant Personal Data will be transferred along with that division and the new owner or newly controlling party will be permitted to use the data for the purposes for which it was obtained.

12. Access to personal information

Individuals can find out if we hold any personal information about them by contacting privacy@capita.co.uk.   

If we do hold information about you, we will;

  • Give you a description of it
  • Tell you why we are holding it
  • Tell you who it could be disclosed to
  • Let you have a copy of the information in an intelligible form.

To make a request for any personal information we may hold you need to put the request in writing using the email address privacy@capita.co.uk or cpi.infosec@capita.co.uk or writing to the address provided in the “who are we?” section of this Notice.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes by using the contact details in the “who are we” section of this Notice.

13. Complaints or queries

We aim to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is inaccurate, unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

If you want to make a complaint about the way we have processed your personal information, you can request a formal internal investigation by contacting privacy@capita.com.  You can also contact the body that oversees Data Protection in the UK – the Information Commissioners Office at https://ico.org.uk/.

14. Your rights

You have the right to be informed about how we will use your information. You also have the right (free of charge) to the following;

  • Access to any personal information we hold about you.
  • To have your information corrected if there are inaccuracies or if the information is incomplete.
  • To restrict the processing of your information in certain circumstances in accordance with applicable law.
  • In some instances, to object to your personal information being used at all due to special grounds relating to your situation. However, there may be compelling reasons why we may need to continue using your information even in these circumstances.
  • To be told if your personal information is lost and if as a result, your privacy and rights may be at risk.

In addition to the above, if we have no legal basis to process your information other than the fact that you gave us your consent, then you have the following additional rights; 

  • To withdraw your consent to process your information.
    In such cases, we will retain the minimum personal data necessary to record that you opted out, to prevent contacting you again.
  • In some instances, to ask for your personal information to be sent to another organisation in a suitable format. For example, we can provide you with your personal information in a structured, commonly used, machine readable form when asked.
  • To withhold permission for your information to be shared.

Please submit any requests about your data to privacy@capita.co.uk

If you have submitted personal information through our capitaproperty.co.uk or glhearn.com websites and wish us to cease using it for the purposes submitted, please contact reimarketing@capita.co.uk

Right to erasure

Under Article 17 of the GDPR individuals have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.

When does the right to erasure apply?

Individuals have the right to have their personal data erased if:

  • the personal data is no longer necessary for the purpose which it was originally collected or processed it for;
  • where we are relying on consent as our lawful basis for holding the data, and the individual withdraws their consent;
  • where we are relying on legitimate interests as the basis for processing, the individual objects to the processing of their data, and there is no overriding legitimate interest to continue this processing;
  • where we are processing the personal data for direct marketing purposes and the individual objects to that processing;
  • where we have processed the personal data unlawfully (in breach of the lawfulness - 1st principle);
  • where we must do it to comply with a legal obligation; or
  • where we have processed the personal data to offer information society services to a child.

You can find out more information about your rights at the Information Commissioner’s Office (ICO) website which can be found at https://ico.org.uk.

15. Disclosure of personal information

There are circumstances in which we may need to share Personal Data. We will not disclose Personal Data without a legal ground to do so and in connections with reason or which we process the data. 

You can also ask us further information on;

  • Agreements we have with other organisations for sharing information.
  • Circumstances where we can pass on Personal Data without consent for example, to prevent and detect crime and to produce anonymised statistics.
  • Our instructions to staff on how to collect, use and delete Personal Data.
  • How we check that the information we hold is accurate and up to date.

16. Changes to this Privacy Notice

We keep our Privacy Notice under regular review. 

This Privacy Notice was last updated in June 2018.  It will be reviewed annually, with the next review due in May 2019.

It may be changed during the year, for example if we introduce a new service, to make sure that it is always current and complete.