John Walne Workplace Investigations and Training Ltd.
Privacy Notice
Introduction
This Privacy Notice explains how John Walne Workplace Investigations and Training Ltd collects, uses, stores and protects personal data. It is intended for website visitors, clients, witnesses, employees of client organisations, training delegates and other individuals whose personal data may be processed during the delivery of services.
Who We Are
The Company provides workplace investigation, grievance, disciplinary, dignity at work, HR consultancy and training services. Depending upon the circumstances, the Company may act either as an independent Data Controller or as a Data Processor acting on behalf of an instructing organisation.
Contact Details
Data Controller: John Walne Workplace Investigations and Training Ltd. Data protection contact: John Walne, Director. Individuals may contact the Company using its published business email address, website contact facilities or business correspondence address.
When We Act as a Controller
The Company is normally a Controller when managing its own business operations, website enquiries, marketing activities, supplier relationships, client administration, invoicing and regulatory compliance. The Company acts as an independent controller where it conducts workplace investigations and reviews.
When We Act as a Processor
The Company may act as a Processor where it conducts training administration or consultancy activities strictly on behalf of a client organisation and in accordance with documented instructions.
Categories of Personal Data
We may process names, contact details, employment information, witness evidence, grievance and disciplinary information, training attendance records, correspondence, financial information and other data relevant to the services provided.
Special Category Data
In investigation and employment matters we may process health information, racial or ethnic origin, religion or belief, trade union membership, sexual orientation or other special category data where necessary and lawful.
Sources of Information
Information may be obtained directly from individuals, clients, managers, witnesses, investigation records, training delegates, publicly available sources and professional advisers.
Purposes and Lawful Bases
Personal data may be processed to deliver contracted services, conduct investigations, deliver training, administer contracts, manage accounts, comply with legal obligations, defend legal claims and pursue legitimate business interests. Depending on the activity, the lawful basis may be contract, legal obligation, legitimate interests or consent.
Article 9 Conditions
Where special category data is processed, relevant conditions may include employment and social protection law obligations, substantial public interest, establishment or defence of legal claims, safeguarding, or explicit consent where required.
Who We Share Data With
Information may be shared with instructing clients, professional advisers, legal representatives, regulators, courts, tribunals, insurers, software providers and other organisations where there is a lawful basis to do so.
International Transfers
The Company uses Microsoft 365 and other business systems that may involve restricted transfers of personal data. Where international transfers occur, appropriate safeguards such as adequacy decisions, International Data Transfer Agreements or approved contractual clauses will be used. You can request a copy of the safeguards by contacting the Data Protection Contact.
Data Security
Appropriate technical and organisational measures include password controls, multi-factor authentication, access controls, Egress secure email, Microsoft security controls, secure cloud storage, anti-malware protection, software updates and secure disposal of records.
Retention
Personal data will be retained only for as long as necessary for the purposes for which it was collected and in accordance with business, contractual, regulatory and legal requirements.
Your Rights
Individuals may have rights of access, rectification, erasure, restriction, objection, portability and rights relating to automated decision-making. These rights are subject to legal exemptions and conditions.
Complaints
If you have concerns about how we process personal data, please contact us first. You also have the right to complain to the Information Commissioner's Office (ICO) at www.ico.org.uk.
Changes to this Notice
This notice may be updated periodically to reflect legal, regulatory or operational changes.
Privacy Notice
