Privacy Policy

How we use your personal information

Your information will be held with Carrington Umbrella Ltd.

This privacy notice is to let you know how we look after your personal information. This includes what you tell us about yourself, what we learn by having you as an employee and the choices you give us about any information and marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

  • To keep your data safe and private
  • Not to sell your data
  • To give you ways to manage and review your marketing choices at any time

Data Protection law will change on 25th May 2018. This notice sets out most of your rights under the new laws. We will update it again between now and 25th May 2018 when changes come into effect.

Who we are

Carrington Umbrella Ltd is a private limited company registered on Companies House. Its registration number is 07816859.

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works. Data Protection law states that we are allowed to use personal information only if we have a proper reason to do so and this includes sharing it outside of Carrington Management Services Ltd. The law says we must have one or more of these reasons:

  • To fulfil a contract with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information but even then, we must not unfairly go against what is right and best for you. If we do rely on our legitimate interest, we will inform you what that is.

Here is a list of all the ways that we may use your personal information and which of the reasons we rely on to do so:

What we use your personal information for Our reason Our legitimate interests
  • To manage our relationship with you or your business.
  • To develop new ways to meet our customers’ needs and to grow our business.
  • To develop and carry out marketing activities.
  • To study how our customers use products and services from us and other organisations
  •  To provide advice or guidance about our products and services.
  • Your consent.
  • Fulfilling contracts.
  • Our legitimate interests.
  • Our legal duty.
  • Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
  • Developing products and services, and what we charge for them.
  • Defining types of customers for new products or services.
  • Seeking your consent when we need it to contact you.
  • Being efficient about how we fulfil our legal duties.
  • To develop and manage our brands, products and services.
  • To test new products.
  • To manage how we work with other companies that provide services to us and our customers.
  • Fulfilling contracts.
  • Our legitimate interests.
  • Our legal duty.
  • Developing products and services, and what we charge for them.
  • Defining types of customers for new products or services.
  • Being efficient about how we fulfil our legal and contractual duties.
  • To deliver of our products and services.
  • To make and manage customer payments.
  • To collect and recover money that is owed to us.
  • Fulfilling contracts.
  • Our legitimate interests.
  • Our legal duty
  • Being efficient about how we fulfil our legal duties and contractual duties.
  • Complying with regulations that apply to us.
  • To detect, investigate, report, and seek to prevent financial crime.
  • To manage risk for us and our customers.
  • To obey laws and regulations that apply to us.
  • To respond to complaints and seek to resolve them.
  • Fulfilling contracts.
  • Our legitimate interests.
  • Our legal duty.
  • Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect.
  • Complying with regulations that apply to us.
  • Being efficient about how we fulfil our legal and contractual duties.
  • To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.
  • Our legitimate interests.
  • Our legal duty.
  • Complying with regulations that apply to us.
  • Complying with regulations that apply to us.
  • To exercise our rights set out in agreements or contracts.
  • Fulfilling contracts.

Groups of Personal Information

We use many different kinds of personal information and group them together like this.

Type of personal information Description
Financial Your financial position, status and history.
Contact Where you live and how to contact you.
Socio-Demographic This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.
Transactional Details about payments to your accounts. 
Contractual Details about the products or services we provide to you.
Locational Data we get about where you are, such as may come from your agency or end client.
Behavioural Details about how you use our products and services.
Technical Details on the devices and technology you use.
Communications What we learn about you from letters, emails and conversations between us.
Usage Data Other data about how you use our products and services.
Documentary Data Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence or birth certificate.
Special types of data The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic and bio-metric data
  • Health data including gender
  • Criminal convictions and offences
Consents Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you, whether you get paper statements, or prefer large-print formats
National Identifier A number or code given to you by a government to identify who you are, such as a National Insurance number

Where we collect personal information from

Data you provide:

  • When you apply to use our services
  • When you talk to us over the phone
  • When you use our website 
  • In email and letters
  • In any annual reviews
  • In any customer surveys

Data from third parties we work with:

  • Agencies that introduce you to us
  • End clients that introduce you to us
  • Social networks
  • Comparison websites
  • HMRC

Who we share your personal information with:

  • Recruitment agencies who have provided the assignment you are working on
  • End clients who have provided the assignment you are working on
  • HM Revenue and Customs, regulators and other authorities
  • Third party service companies who we use to provide services to you e.g. Clickatell to send you a text to confirm you have been paid
  • System companies who we use to provide our service to you
  • Companies that you ask us to share data with

We may also share your personal information if the make-up of Carrington Management Services Ltd changes in the future:

  • We may choose to sell, transfer or merge parts of our business or our assets. Or we may seek to acquire other businesses or merge with them.
  • During any such process we may share your data with other parties. We will only do this is they agree to keep your data safe and private.
  • If a change to Carrington Management Services Ltd happens then other parties may use your data in the same way as set out in this notice.

How we use your information to make automated decisions

Where we collect personal information from

We may collect personal information about you (or your business) from other companies within the 

Carrington Group and from these sources:

Data you give to us:

  • When you apply for our products and services
  • When you talk to us on the phone
  • When you use our websites
  • In emails and letters
  • In customer surveys

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

  • Payment and transaction data
  • Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services

Data from third parties we work with:

  • Companies that introduce you to us
  • Financial advisers
  • Comparison websites
  • Social networks
  • Fraud prevention agencies
  • Payroll service providers
  • Public information sources such as Companies House
  • Agents working on our behalf
  • Government and law enforcement agencies.

Who we share your personal information with

We may share your personal information with companies within the Carrington Group and these organisations:

  • Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
  • HM Revenue & Customs, regulators and other authorities
  • Fraud prevention agencies
  • Any party linked with you or your business’s product or service
  • Companies we have a joint venture or agreement to co-operate with
  • Organisations that introduce you to us
  • Companies that we introduce you to
  • Independent Financial Advisors
  • Companies you ask us to share your data with

We may also share your personal information if the make-up of Carrington Management Services Ltd changes in the future:

  • We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
  • During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
  • If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

How we use your information to make automated decisions

We sometimes use systems to make automated decisions based on personal information we have  or are allowed to collect from others – about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.

Here are the types of automated decision we make:

Pricing 


We may decide what to charge for some products and services based on what we know.

Tailoring products and services

We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.

Your rights

As a person you have rights over automated decisions.

  • You can ask that we do not make our decision based on the automated score alone.
  • You can object to an automated decision and ask that a person reviews it.

If you want to know more about these rights, please contact us.

Identity Checks

We carry out identity checks when you apply to use our service and become an employee.

We’ll use this data to:

  • Assess that you are who you say you are
  • Make sure what you’ve told us is true and correct
  • Help detect and prevent financial crime
  • Ensure you have the right to work in the UK
  • Help prevent fraud and money-laundering

The information we use

These are some of the kinds of personal information that we use:

  • Name
  • Date of birth
  • Residential address
  • Contact details, such as email addresses and phone numbers
  • A copy of your passport including the outer page
  • A copy of your driving license 
  • A copy of a utility bill or bank statement showing your name and address

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us at any time.

Whatever you choose, you’ll still receive payslips, and other important information such as P60’s and updated terms of employment.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.  If you change your mind you can update your choices at any time by contacting us.

How long we keep your personal information:

We will keep your personal information for as long as you are an employee of Carrington Management Services Ltd

After you stop being a customer, we may keep your data for up to 7 years for one of these reasons:

  • To respond to any questions or complaints.
  • To show that we treated you fairly.
  • To maintain records according to rules that apply to us.

How to get a copy of your personal information

You can access your personal information we hold by writing to us at our address – Carrington Umbrella Ltd, Birchin Court, 20 Birchin Lane, London EC3V 9DU or emailing us at contact@carringtonumrella.co.uk 

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

  • It is not accurate.
  • It has been used unlawfully but you don’t want us to delete it.
  • It not relevant any more, but you want us to keep it for use in legal claims.
  • You have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data or ask us to delete it or restrict how we use it or, please contact us.

How to withdraw your consent

You can withdraw your consent at any time. Please contact us if you want to do so.  If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us at our address or by emailing contact@carringtonumbrella.co.uk.  You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

Future formats for sharing data

The Data Privacy laws changed on 25 May 2018. From that date you will have the right to get your personal information from us in a format that can be easily re-used.

You can also ask us to pass on your personal information in this format to other organizations.  We are working with our industry to improve the way your data is shared. 

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