Your privacy and the security of your personal information are very important to us.
County Nannies Ltd is registered as a data controller with the UK supervisory authority for data protection, The Information Commissioner’s Office (ICO). Registration No: Z9869823
County Nannies processes information in accordance with the principles of data protection.
Why and how do we process personal data?
We will collect all personal details that you provide to us via our website; on application forms; by post or email; over the phone; in interviews; and provided to us by your referees. This information includes any supplementary material you may provide such as, but not limited to, family photographs.
Data will be stored in a range of different places, including on your application file and on other IT systems (including email) in both paper and electronic formats.
We will process data only where the processing of such data is necessary for the performance of our obligations. When submitting your personal information to us, you are aware that we may share this data with client families/candidates where in our professional opinion a suitable placement may be made.
County Nannies has a legitimate business interest in processing personal data in order to provide recruitment services and for keeping records of the process. Processing data from families and candidates allows us to manage the introduction procedure, to assess and confirm a family’s suitability to take on a childcarer/Au Pair and to assess and confirm a candidate’s suitability to perform the role of childcarer/Au Pair. It allows us to keep families informed of available candidates and to keep candidates informed of available families.
For candidates, we are obliged to seek information about criminal convictions and offences. This is necessary in order for us to carry out our obligations.
We need to process personal data in order to submit invoices and manage payment of fees and charges.
Where we have taken up personal references we may, with the referee’s consent, share that reference with families or childcarers/Au Pairs for the purposes of making a placement. That reference may include personally identifiable data about the referee.
Where we rely on legitimate business interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of families and candidates. We have reached the conclusion that they are not.
Special notice to families seeking an au pair
In order to fulfil our obligations as an Au Pair agency, it is necessary to work with third party partner agencies in Europe and for them to see and be privy to the information provided on our Client Family Application Form, as well as any supplementary material you may have supplied to us including, but not limited to, family photographs. We require all third parties to whom we transfer this information to respect the security of your personal data and to treat it in accordance with the law. We instruct these third parties to process your personal data solely for the specified purpose.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to County Nannies during the introduction process. However, if you do not provide the information, we may not be able to process your application properly or at all.
For how long do we keep data?
Where placements have been successfully made, we will securely store your data for six years from the date we provided you with our services. Six years is the statute of limitation in terms of contractual disputes. County Nannies has also assessed the reasonable length of time to keep data where the care of children is involved, given that there is no legal recommended time for this. Our review concluded that six years is a fair and reasonable period – unless legislation is subsequently passed setting out the required length of time to keep records on childcare recruitment.
If a safeguarding issue has ever been brought to our attention in relation to a childcarer/Au Pair or client registered with us, we have taken the view that data should never be erased permanently. The protection of vulnerable children is paramount.
Where placements have not been made, we will securely store your data for one year from the date you provided us with your personal information. This is to ensure that we are able to respond to any alleged discrimination claims. You have certain rights to request that we delete all data we hold on you. Please refer to the section headed ‘Your rights’.
In the case of Au Pairs not placed by us who are registered with third party partner agencies, rather than with County Nannies directly, we will delete their files as soon as we are advised that the Au Pair is no longer available.
Security of your personal data
We have taken appropriate organisational and technical measures to protect your privacy from unauthorised access and improper use of your personal data. However, it should be noted that communication over the internet or via email can never be regarded as 100% secure and we therefore cannot guarantee the absolute security of your private information.
We have summarised below the rights you have under data protection law. Some of the rights are complex, and not all of the details have been included. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
a) You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
b) You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
c) In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for compliance with a legal obligation; for the establishment, exercise or defence of legal claims; or where there is any safeguarding issue (or safeguarding allegation) relating to a childcarer/Au Pair or client.
d) In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another person; or for other compelling legitimate grounds.
e) You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
f) To the extent that the legal basis for our processing of your personal data is consent or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
g) If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the ICO.
h) To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified above.
Any dispute which may arise over privacy will be subject to this policy and the provisions of English law, including the General Data Protection Regulation (GDPR).
Should you wish to make a data privacy enquiry or complaint, please contact us in writing either by post to: County Nannies Ltd, Cherry Gardens, Nouds Lane, Lynsted, Kent ME9 0ES. Or by email to: firstname.lastname@example.org
© County Nannies Ltd February 2021
Directors: Benedicte Speed (Managing) • Julien Speed • Sylvia Speed (Secretary)