Privacy Notice

Personal Data

“Personal Data” is data which relates to a living individual who can be identified from that data.

Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).

This privacy notice describes the personal information Shorterm may hold about you, the reasons why it held, what Shorterm might do with the data. If you have any questions about this privacy notice, then please contact the Data Protection Officer. They can be contacted either via email to gdpr@shortermgroup.com or via post to the Data Protection Officer at the address below.

This privacy note is current as of 25 May 2018, and it may be updated from time to time. Accordingly, you are advised to check this section for changes.

Who we are

Shorterm Limited (“Shorterm”), including or on behalf of its group companies (which includes Trainspeople Ltd), is the data controller. This means Shorterm decides how your personal data is processed and for what purposes.

Shorterm Limited is registered at The Barn, Philpots Close, Yiewsley, Middlesex UB7 7RY, England.

Shorterm complies with our obligations under the GDPR by:

- taking steps to ensure personal data is up to date;
- storing it securely, and destroying it when necessary;
- taking steps to ensure we do not collect or keep more personal data than necessary;
- taking technical and practical steps to protect personal data, so that it is kept secure and is not lost or inadvertently/unlawfully disclosed or accessed;
- taking steps to ensure that you are aware of what we do with personal data; and
- giving you the opportunity to change how, what or whether we hold personal data about you (subject to the terms of this privacy notice). 

 

How Shorterm uses Personal Data

How personal information is collected, held and processed (including transferred) depends upon the type of information we hold – that is, who provided it, and why it is needed.

1. Personal Data about individuals applying for roles (“Candidate Information”);
2. Personal Data about individuals who have carried out services for Shorterm (“Contractor Information”);
3. Personal Data about individuals who work for clients or suppliers (“Client Information”);
4. (in relation to Shorterm’s training business only) Personal Data about individuals applying to participate on a training course and/or those who participate on a training course (“Attendee Information”);
5. (in relation to Shorterm’s training business only) Personal Data about individuals who wish to provide training via Shorterm (“Trainer Information”).
6. Personal Data about our current and former employees (“Employee Information”)

  

Candidate Information

Shorterm may hold the following information about Candidates

- personal identification (passport, driving licence, work permit)
- contact details (address, telephone numbers and email)
- work history (including references)
- details of qualifications and experience
- medical records*
- criminal record*

*Medical and Criminal record information means a medical/health check and a background check in respect of criminal records. These will only be obtained where it is relevant in respect of a particular role – for example, for work on a safety critical role, or where a role requires specific security/background checks (such as work at an airport). You will always be informed in advance if a client has requested these checks. You may decline the checks, but it may mean that you are no longer able to carry out the role. Any medical or criminal record information will be held securely by Shorterm, and will only be passed to the client which has requested the information.

How we obtain Candidate information

1. It may be provided by the Candidate
2. The Candidate’s referees’ (in respect of work history or qualifications)
3. Public bodies (such as regulatory bodies, health professionals or the police)
4. Third party websites, where a Candidate has posted their CV/resume or other details of their qualifications/experiences for consideration for roles.

This information is held for the following purposes:

1. to consider a candidate for current or future roles
2. to comply with regulatory/industry requirements

 

Transfers of Candidate Information

Shorterm uses most information for its internal purposes only – that is, to check suitability of a Candidate for actual and potential roles with Clients.

If a candidate is considered suitable for a potential role Shorterm may transfer their personal information to the potential client.

This will ONLY be done, if a Candidate has agreed to be put forward for the role (in accordance with the “consent” basis of the GDPR

Shorterm may also transfer Candidate information to the following entities for the following specific purposes, which are also lawful under Article 6 of the GDPR):

1) to a payroll company, in order to facilitate payment to the Candidate if they become a Contractor (see Contractor Information below) (in accordance with the “contract” basis for processing data under the GDPR.

2) to the police, court or regulatory bodies (in accordance with the “legal requirement” basis for processing data under the GDPR. Please note, for individuals applying to carry out work on the Network Rail infrastructure or for roles which require particular security clearance, this will also include sharing information with Network Rail or other nominated or responsible regulatory/supervisory entity in order to comply with the Sentinel Scheme or other applicable rules.

3) to third party “app” or other online software provider(s) which facilitate the communication and/or provision of electronic contract information to Candidates and Clients on behalf of Shorterm. Where such providers are used Shorterm contractually obliges these third parties to:

a. treat all data securely;
b. process them in accordance with the GDPR (or the EU’s approved standard model contracts or other approved basis, if the provider is outside of the EU);
c. use the data only in relation to Shorterm, and not sell or transfer personal information to any third parties.

 

Contractor Information

Shorterm may hold the following information about Contractors

Their relevant Candidate Information, being

- personal identification (passport, driving licence, work permit)
- contact details (address, telephone numbers and email)
- work history (including references)
- details of qualifications and experience
- medical records*
- criminal record*

*Medical and Criminal record information means a medical/health check and a background check in respect of criminal records. These will only be obtained where it is relevant in respect of a particular role – for example, for work on a safety critical role, or where a role requires specific security/background checks (such as work at an airport). You will always be informed in advance if a client has requested these checks. You may decline the checks, but it may mean that you are no longer able to carry out the role. Any medical or criminal record information will be held securely by Shorterm, and will only be passed to the client which has requested the information.

Details of work on assignments, including:

- Pay
- Hours worked
- Performance record
- Disciplinary record
- Absenteeism

How we obtain Contractor Information

1. It may have been gathered as part of Candidate Information
2. Client or other line manager reports
3. Client’s HR departments
4. The Contractor’s payroll, umbrella, or service company
5. Public bodies (such as regulatory or industry bodies, health professionals or the police)

This information is held for the following purposes:

1. to consider the Contractor’s suitability in their current role
2. to consider the Contractor for alternative current or future roles
3. to comply with regulatory/industry requirements

 

Transfers of Contractor Information

Shorterm uses most information for its internal purposes only – that is, to check suitability of a Contractor in their current role, and for any alternative actual and potential roles with Clients.

If a Contractor wishes to be considered for alternative roles, they will become a Candidate in respect of that role – in such cases the processing is dealt with in the Candidate Information section.

Shorterm may also transfer Contractor Information to the following entities for the following specific purposes, which are also lawful under Article 6 of the GDPR):

1. to the Candidate’s payroll, umbrella or service company, in order to facilitate payment to the Contractor or to deal with any contractual issues with the Contractor (in accordance with the “contract” basis for processing data under the GDPR)
2. where applicable, to the supplier of benefits to the Contractor, such as a pensions provider, if the Contractor falls within the provision of Shorterm’s pension scheme (in accordance with the “legitimate interest” basis for lawful processing under the GDPR);
3. to HMRC, the police, court or regulatory/industry bodies (in accordance with the “legal requirement” basis for processing data under the GDPR). Please note, for individuals carrying out work on the Network Rail infrastructure or in any role which requires particular security clearance, this will also include sharing information with Network Rail or other nominated entity in order to comply with the Sentinel Scheme or other applicable rules or regulations.
4. to third parties if Shorterm has been nominated by the Contractor as a referee (as listing Shorterm as a referee inherently is a matter determined by the Contractor themselves, as such this would be under the lawful basis of “consent” under the GDPR), or where Shorterm is required to provide a reference by law/regulation (for example in relation to roles requiring particular security clearance), this will be on the basis of “legal requirements”.
5. to third parties if Shorterm loses the Client account on which the Contractor is working, but the Contractor may be subject to a transfer to the new supplier under the Transfer of Undertakings (Protection of Employment) Regulations (as such this is processing on the lawful basis of complying with “legal requirements”)
6. to third party “app” or other online software provider(s) which facilitate the communication and/or provision of electronic contract information to Contractors on behalf of Shorterm. Where such providers are used Shorterm contractually obliges these third parties to:

a. treat all data securely;
b. process them in accordance with the GDPR (or the EU’s approved standard model contracts or other approved basis, if the provider is outside of the EU);
c. use the data only in relation to Shorterm, and not sell or transfer personal information to any third parties.

 

Client Information

Shorterm may hold the following personal information about Clients

- name
- contact details (work address, telephone numbers and email)

How we obtain Client information

1. It may be provided by the Client
2. It may be provided by a Contractor or Candidate
3. Third party websites, where a Client’s contact details have been posted

This information is held for the following purposes:

1. to consider whether a client may wish to receive services from Shorterm;
2. to manage the provision of services by Shorterm to the Client (or vice versa in the case of a supplier)
3. to comply with regulatory requirements

 

Transfers of Client Information

Shorterm uses Client Information for its legitimate internal business purposes only – that is, to manage the provision of services pursuant to an actual or potential contract with the client.

Shorterm will only transfer Client Information for the following specific purposes, which are also lawful under Article 6 of the GDPR):

1. to a Candidate or Contractor as is necessary for fulfilling the contractual obligations between Shorterm, the Client and/or the Contractor/Candidate (the “contract” basis); or
2. to the police, court or regulatory bodies (in accordance with the “legal requirement” basis for processing data under the GDPR) Customers.

 

Attendee Information

The following is applicable in relation to Shorterm’s training business only.

Shorterm may hold the following information individuals who apply to attend or who actually attend a training session run or organised by any entity within the Shorterm group of companies.

Attendee Information may include :

- personal identification (passport, driving licence, work permit)
- contact details (address, telephone numbers and email)
- work history
- details of qualifications and experience
- record of attendance on a training course
- performance / outcome of the individual on a training course

 How we obtain Attendee Information

- Provided by the Attendee themselves;
- Provided by the Attendee’s employer, governing organisation or similar entity on behalf of the Attendee.

This information is held for the following purposes:

- to consider the Attendee’s suitability or qualifications for a training course
- to consider the Attendee’s performance on a training course;
- to comply with regulatory, governing or authorising body requirements;
- for Shorterm’s internal record keeping (its legitimate business interests).

 

Transfers of Attendee Information

Shorterm uses the Attendee Information primarily to check Attendees are able to attend a course, and confirm their performance on the course.

Shorterm may also transfer Attendee Information to the following entities for the following specific purposes, which are also lawful under Article 6 of the GDPR):

- to the Attendee’s employer or organisation which has sent or paid for the Attendee to attend the course (in accordance with the “contract” basis for processing data under the GDPR);
- to the governing or regulatory body which confirms, approves or authorises attendance and performance on the course, which is necessary as a result of the contract with either the Attendee themselves or their employer or organisation which has sent or paid for the course (in accordance with the “contract” basis for processing data under the GDPR);
- to the individual who provides the training (which may be an individual employed or alternatively engaged via an entity within the Shorterm group), so that they may use the information in order to allow attendance and record performance on the course (in accordance with the “contract” basis for processing data under the GDPR);
- to third party “app” or other online software provider(s) which facilitate the communication and/or provision of course information to Attendees on behalf of Shorterm. Where such providers are used Shorterm contractually obliges these third parties to:

a. all data securely;
b. process them in accordance with the GDPR (or the EU’s approved standard model contracts or other approved basis, if the provider is outside of the EU);
c. use the data only in relation to Shorterm, and not sell or transfer personal information to any third parties.

 

Trainer Information

The following is applicable in relation to Shorterm’s training business only.

Shorterm may hold the following information individuals who apply to or actually provide training sessions on behalf of Shorterm.

Trainer Information may include :

- personal identification (passport, driving licence, work permit)
- contact details (address, telephone numbers and email)
- work history (including references)
- details of qualifications and experience
- record of delivering training course(s)
- performance / outcome of training

How we obtain Trainer Information

- Provided by the Trainer themselves;
- Provided by the Trainer’s employer, referee, governing organisation or similar entity.

This information is held for the following purposes:

- to consider the Trainer’s suitability or qualifications to provide a training course for Shorterm’s Attendees
- to evaluate the Trainer’s performance in delivering a training course
- to comply with regulatory, governing or authorising body requirements
- for Shorterm’s internal record keeping (its legitimate business interests)

 

Transfers of Trainer Information

Shorterm uses the Trainer Information primarily to record which services a Trainer has provided to Attendees on behalf of Shorterm.

Shorterm may also transfer Trainer Information to the following entities for the following specific purposes, which are also lawful under Article 6 of the GDPR):

- to the Trainer’s employer or organisation which has provided the Trainer, which may include an umbrella or payroll company (in accordance with the “contract” basis for processing data under the GDPR);
- to the governing or regulatory body which confirms, approves or authorises Trainers to deliver training courses (in accordance with the “legitimate interest” basis);
- to the Attendees, so that they may attend the training provided by the Trainer (in accordance with the “contract” basis under the GDPR).
- In response to reference requests (on the “consent” basis if the reference was requested/offered by the Trainer, or on the basis of “legal requirement” where the reference was requested by a regulatory or governing body)
- to HMRC in respect of payments made to the Trainers (in accordance with the “legal requirement” basis under the GDPR).
- to external providers of benefits, if the Trainer is entitled to such, for example to pensions providers if the Trainer falls within Shorterm’s pension provision.

 

Employee Information

If you have any questions in relation to the personal information being held about you by Shorterm, or would like to make any changes, please refer in the first instance to the Employee Handbook.

Shorterm may hold the following information about Employees

- personal identification (passport, driving licence, work permit)
- contact details (address, telephone numbers and email)
- work history (including references)
- details of qualifications and experience
- medical records*
- criminal record*

*Medical and Criminal record information means a medical/health check and information received or recorded in respect of criminal records. These will only be obtained where it has become necessary during your employment – for example, if you have provided a doctor’s note in respect of a period of absenteeism, or if you are dismissed as a result of criminal activity. Any medical or criminal record information will be held securely by Shorterm, and will only be used for our internal purposes, save where it needs to be forwarded for regulatory or legal purposes, or pursuant to a response for a reference.

Details of your employment with Shorterm, including:

- Remuneration and benefits
- Hours, dates worked
- Performance record
- Disciplinary record
- Absenteeism

How we obtain Employee information:

The information may be provided by:

- the Employee
- the Employee’s line manager, or Clients
- Shorterm’s HR department
- Public bodies (such as regulatory or industry bodies, health professionals or the police)

This information is held for the following purposes:

- to consider the Employee’s suitability in their current/most recent role (the “legitimate interest” basis)
- to consider the Employee for alternative current or future roles (the “legitimate interest” basis)
- to comply with regulatory/industry requirements (the “legal obligation” basis )
- to manage the employment relationship, including the calculation and payment of salary and benefits (the “legitimate business interest” basis ”
- to comply with employment laws and regulations (the “legal obligation” basis).

 

Transfers of Employee Information

Shorterm uses most information for its internal purposes only – that is, to manage its rights and obligations in its employment relationship with you.

Shorterm may transfer Employee Information to the following entities for the following specific purposes, which are also lawful under Article 6 of the GDPR):

- to a third party provider or payroll services or employee benefits, in order to facilitate payment to the Employee (in accordance with the “contract” basis for processing data under the GDPR)
- to the police, court or regulatory bodies (in accordance with the “legal requirement” basis for processing data under the GDPR)
- to third parties if we receive a request for a reference (where requested by you, this would be on the basis of “consent”, and where required by law this would be on the basis of “legal requirement” )
- to third parties in order to comply with TUPE obligations (Transfer of Undertakings, Protection of Employment), in the event that Shorterm loses a relevant contract, and your role is considered dedicated to such contract. Employee Information will be transferred to the incoming service provider due on the basis of meeting our “legal requirements”
- to third party “app” or other online software provider(s) which facilitate the communication and/or provision of personal testing of Employee on behalf of Shorterm. Where such providers are used Shorterm contractually obliges these third parties to:

a. treat all data securely;
b. process them in accordance with the GDPR (or the EU’s approved standard model contracts or other approved basis, if the provider is outside of the EU);
c. use the data only in relation to Shorterm, and not sell or transfer personal information to any third parties.

 

Lawful Basis for Processing

GDPR Article 6 sets out the only basis on which processing of Personal Data is lawful.

Shorterm relies on the following lawful basis:

1) Consent

Shorterm will always ask for explicit consent for two specific parts of the processing of “Candidate Information”:

- prior to putting forward a Candidate for a role; and
- in order to put Candidate details on Shorterm’s database.

You may withhold or withdraw your consent at any time, in accordance with the procedure set out in this privacy notice.

PLEASE NOTE: if you withhold or withdraw your consent, Candidate/Contractor Information will not be used or transferred for the purpose of searching for appropriate roles (that specific type of processing). However, the Personal Data held as part of Candidate or Contractor Information may still be stored and processed by Shorterm, if and to the extent necessary to fulfil its other obligations (for example, in relation to legal claims or in relation to financial record keeping) – such further processing will be on one of the following basis.

2) Contract

Where Shorterm is processing Personal Data in order to fulfil obligations under a contract with you, then this will be the lawful basis for such processing.

Shorterm has contracts with candidates, and Contractors (which may include the Contractor’s representatives/employers/companies). Shorterm will process Candidate and Contractor Information in order to fulfil our obligations under those contracts. That would include, for example, transferring Personal Data to a payroll company in order to ensure a Contractor is paid for the work they have done.

Shorterm has contracts with its clients. In order to fulfil our obligations to clients, we will need to pass certain Client Information to Candidates or Contractors (for example, the contact details of Human Resource staff for Candidate interviews, Shift/Line Managers to Contractors when the commence work, or Client Representatives for queries from Shorterm’s client relationship team) or to payroll (for example, contact details from the client’s finance department).

3) Legal Obligation

Shorterm will process Personal Data in order to comply with the law. This includes obligations to maintain accurate and historic financial records and /or respond to and manage legal claims or threats (in each case subject to relevant statutory limitation periods).

Shorterm will also transfer Contractor Information in order to comply with TUPE obligations (Transfer of Undertakings, Protection of Employment), in the event that Shorterm loses a relevant contract. Contractor Information will be transferred to the incoming service provider.

4) Legitimate Interests

Shorterm maintains a database of Candidate, Contractor and Client Information. It does not transfer or sell this information to any third parties, save in the instances set out above. However, it does hold this information, and may use it for searching for business opportunities.

PLEASE NOTE - As explained in relation to consent – no Candidate or Contractor Information will be transferred to third parties in relation to roles / opportunities without the Candidate or Contractor’s consent.

All database information will be held securely, and not kept for longer than is necessary.

 

How long we keep your Personal Data

Shorterm stores Personal Data for periods which are necessary and reasonable depending upon the nature of the data, and the reason for which it is being stored. The following table sets out the current retention periods being used by Shorterm for Personal Data held for various purposes. Please note, these periods are subject to review and the table may be amended from time to time:

Reason

Retention Period

If you have provided services to, or on behalf of Shorterm

7 years from conclusion

If you attended a course

7 years from the last day of the course

If you have received services from Shorterm

7 years from the last date on which services were provided

If you were employed by Shorterm

7 years from the termination of your employment

If you registered your CV with Shorterm but did not take up a role

4 years from the date on which your most recent application was unsuccessful

If you applied for a role but did not provide services

4 years from the date on which your most recent application was unsuccessful

If you registered interest in a course, but did not attend/deliver the course

4 years from the date on which you most recently registered an interest in a cours


Please note, the above retention periods are in relation to Shorterm’s active database only.

This means that Shorterm will not contact you in relation to providing services or courses after the above dates.

If you wish Shorterm to contact you after these dates, you will have to renew your contact with Shorterm, and resubmit any personal information provided.

Please note, in addition to the above retention periods, Shorterm may retain archive copies of personal information beyond those dates, solely in relation to handling legal claims or legal requirements. It will not be sold or transferred or otherwise used for alternative purposes.

 

Procedural and Technical Safety Measures

In order to ensure all Personal Data is held securely, Shorterm has the following procedural and technical safety measures:

- all data provided to Shorterm is stored on secure servers that are located in the UK. Appropriate security protection measures for all forms of data protection and business continuity are in place. 
- access to the Shorterm's systems is controlled by secure login procedures. Access permissions are resticted and controlled. Usernames and passwords are to be uniquely assigned to named individuals and regularly changed to ensure protection. 
- all websites operated by Shorterm are protected with Standard Secure Layer (SSL) Encryption Technology. Where external user access is provided to any part of our websites we issue secure access passwords.
- all staff have received training in data protection and data protection forms part of our ongoing employee induction programme.

 

Contacting us about Personal Data we hold

If you want to contact us in respect of this policy, or the data we may hold about you, we can be reached at the following email address: gdpr@shortermgroup.com

Or via post to: The Data Protection Officer, Shorterm Limited, The Barn, Philpots Close, Yiewsley UB7 7RY England.

In addition to general questions you may have about either this policy or our processing of personal data, you may wish to ask about the following:

1)  receiving copies of certain personal data (“Relevant Information”) we hold about you

a. This is known as a “data subject access request”. If you would like to make a data subject access request:

i. You must write to The Data Protection Officer, Shorterm Limited, The Barn, Philpots Close, Yiewsley UB7 7RY England informing us that you are making such a request. In order to ensure that we only provide copies of information to you, please enclose a certified colour copy of either your passport or driving license.

ii. Shorterm will carry out a reasonable search for Relevant Information held, so when making the request, it would be helpful for you to be as specific as possible in respect of the information you are seeking: for example, in terms of periods covered, and types of data held. This makes it more likely that Shorterm can locate the information which is most relevant for you. If you do not provide any detail as to the information you are seeking, Shorterm may contact you to ask for further details about your request.

iii. The search will be carried out within a month of receiving the confirmation set out in points i) and ii) above, unless the search you have requested is particularly complex, or the amount of information is unusually large (we will inform you of such within the month).

iv. Relevant Information is information on Shorterm’s electronic or structures manual files which is about you. This means that it will be information which records something tangible about you, rather than just listing your name. For example, a file in recording your performance on an assignment is likely to be Relevant Information, whereas your email address being in a list of numerous other recipients of an electronic mail shot is unlikely to be Relevant Information.

v. There are various exemptions which mean that your personal information may not be disclosed as Relevant Information. These can be found on the Information Commissioner’s Website https://ico.org.uk, but some common exemptions are when the information contains a third party’s personal information (and such third party does not consent to disclose such), where searching for and disclosing information requires a disproportionate effort, or where a document has legal professional privilege.

 

2) updating or amending personal data we hold about you

a. if you believe the Personal Data we hold is inaccurate or out of date, we would be grateful if you could let us know. This will also help ensure that Shorterm is not processing incorrect data about you.

i. To update or amend your Personal Data please contact us either via email to gdpr@shortermgroup.com or via post to The Data Protection Officer, Shorterm Limited, The Barn, Philpots Close, Yiewsley UB7 7RY England.

ii. Shorterm may ask to verify your identity.

iii. Within one month of receiving such verification, Shorterm will review the amended or updated information provided by you, including where relevant, asking for confirmation/verification from relevant third parties.

iv. If there is a delay in verification or otherwise amending the Personal Data, Shorterm will contact you within the one month period, explaining the grounds for any such delay.

v. Once the updated or amended information has been verified, Shorterm shall amend its systems accordingly. The expired/inaccurate Personal Information shall be removed from the active systems, but a copy may be retained for archive and maintenance of records only (see “Legal Obligations” basis for processing).

vi. Please note, during any period of verification your Personal Data will continue to be processed in the unamended form until verification has been complete.

vii. At the end of any verification, Shorterm shall contact you to inform you how your Personal Data has been updated/amended.

 

3) You have the right to request for your Personal Data to be blocked, pending the above requests. This would mean that Shorterm would not contact you about any roles or otherwise process your data (save to the extent necessary to meet its legal or regulatory obligations, or deal with actual or potential litigation), until the above steps have been completed.removing your consent for Shorterm to process certain data about you

a. Shorterm processes certain information on the “consent basis”:

- being put forward for a role;
- being placed on Shorterm’s database for consideration for roles;
- in order to attend a training course (relevant for Shorterm’s training businesses only);
- in order to provide a training course (relevant for Shorterm’s training businesses only);
- in order to provide a reference.

b. You are free at any time to amend or withdraw your consent to all or part of the relevant processing. If you wish to do so, the following process applies:

i. You must contact Shorterm at gdpr@shortermgroup.com informing us that you have changed your consent preference in respect of one or more of the above areas.

ii. Shorterm will respond within 10 working days, to verify your identity and request.

iii. Once your identify and request has been acknowledged and confirmed, Shorterm will amend its system processes in relation to your Personal Data accordingly. Please note, if you withhold or withdraw your consent, Candidate/Contractor Information will not be used or transferred for the purpose of searching for appropriate roles (that specific type of processing), or in relation to the offering or provision of training courses. However, the Personal Data may continue to be stored and processed by Shorterm, if and to the extent necessary to fulfil its other obligations as set out elsewhere in the policy (for example, in relation to legal claims or in relation to financial record keeping) – such further processing will be on one of the lawful basis set out at the start of the policy.

c.  When making the above request, you may also request for your Personal Data to be blocked, pending the above steps. This would mean that Shorterm would not contact you about any roles or otherwise process your data (save to the extent necessary to meet its legal or regulatory obligations, or deal with actual or potential litigation), until the above steps have been completed.

4)  requesting that Shorterm transfers your personal data to another entity.

a. Where you have provided Shorterm with Personal Data, you can request that Shorterm transfers that Personal Data to a third party (for example, another employment agency) (the “Transferring Data”). In order to do this, the following process applies:

i. You must write to the Data Protection Officer, Shorterm Limited, The Barn, Philpots Close, Yiewsley UB7 7RY England providing details of the third party to whom you wish Shorterm to transfer the “Transferring Data”).

ii. The Transferring Data should include Personal Data which:

1. is processed via an automated means; and
2. you provided to Shorterm; and
3. has been processed under the lawful basis of either:

a. “consent” or
b. “contract”.

iii. Shorterm will contact you within 10 working days to confirm the fact and details of your request.

iv. Once Shorterm has received the above confirmation, Shorterm will make a copy of the Transferring Data on a commercially generally available format (for example Microsoft Word, Microsoft Excel) and will send a copy to the contact details you have provided.

v. After carrying out step iii) above, Shorterm will send you an email confirming what Personal Data was transferred to the third party.

b. When making the above request, you may also request for your Personal Data to be blocked, pending the above steps. This would mean that Shorterm would not contact you about any roles or otherwise process your data (save to the extent necessary to meet its legal or regulatory obligations, or deal with actual or potential litigation), until the above steps have been completed.