Data Privacy Notice (issue date: 23/5/18)
As a prospective Morses Club Agent please take the time to read and understand this privacy notice as it contains important information about the information we collect about you during the Agency application process and what we use it for.
We are committed to respecting your privacy and this notice explains how we may use the personal information we collect about you during the Agency application process. It also explains how we comply with the law on data protection and what your rights are. A separate and replacement privacy notice will be provided to you to cover your contractual relationship with us if we subsequently offer you an Agency role with us.
Morses Club PLC is registered in England and Wales (Registration No 06793980) and our registered address is Kingston House, Centre 27 Business Park, Woodhead Road, Birstall, WF17 9TD and we are authorised and regulated by the FCA.
Under the General Data Protection Regulations (GDPR) we are the ‘Data Controller’ for the information you provide when you apply for an Agency with us. ‘Data Controller’ is a legal phrase used to describe the person or entity that controls the way information is used and processed.
Our Data Protection Officer oversees our compliance with data protection laws and if you are unhappy with the way we have handled your data at any time you will find details of how to contact them in the “Contacting us” section at the end of this privacy notice.
We collect the following personal information from you when you initially apply for an Agency role with us:
- Title, first name and surname;
- Email address;
- Telephone numbers;
- Address & postcode;
- whether you have a valid UK driving licence
If we arrange to meet with you to discuss your becoming an Agent, or we subsequently offer you an Agency role with us we will also collect additional information to enable us to set you up on our systems and fulfil our contractual and legal obligations in relation to your Agency role, which will be detailed in our Agents privacy notice, for example we may collect:
- national insurance number;
- date of birth;
- emergency contact details;
- copies of identification documents such as passport, utility bills, driving licence;
- previous addresses
We require this information to complete our necessary checks before we offer you an agency.
Whenever we collect your personal information we will always aim to make it clear whether it is necessary for you to provide it or whether it is optional but if you are unsure at any time please ask.
If you require a copy of the Agents’ privacy notice you can e-mail MCLAgent.Support@morsesclub and we will arrange to send you a copy.
Special Category Personal Information
We may also collect, store and use “special categories” of more sensitive personal information about you during the Agency application process. This includes information about your:
- criminal convictions (including driving convictions)
- credit history
We collect the above information on the basis that it is necessary for:
- the purposes of carrying out our legal obligations or
- you have given your explicit consent to this information being processed.
You are not under any obligation to provide us with any of your personal information, and you do not have to agree to any request for consent from us. However if you choose not provide information or you withdraw your consent this may prevent us from processing your Agency application further or confirming an offer of an Agency.
If you have given consent for us to use your personal information in a particular manner, you have the right to withdraw this at any time. If you decide to do we may still be entitled to hold and process the relevant personal information on a basis other than your consent (e.g. where we have a legal obligation to do so) it will also not affect any use of the data made by us before you withdrew consent.
If you wish to withdraw your consent you can e-mail MCLAgent.Support@morsesclub at any time and ask us to remove the data you do not wish us to process.
Data Collection and Usage
We typically collect personal information from you during the application and engagement process, using our website, over the telephone, email and face to face. We also collect additional information from third parties including credit reference agencies or other background check agencies.
You should note that if, as part of the Agency application and engagement process, you provide us with details of family members and emergency contacts, it is your responsibility to ensure you have their permission to provide us with this information as they also have a right to know and to be aware of what personal information we hold about them, how we collect it, how we use and how we may share that information.
They also have the same rights as set out in the “Your rights in relation to personal information” section.
The main purposes for which we collect your personal information for during the application and engagement process, the categories of information we use for each purpose and our lawful basis for collecting and processing it is set out in the table below.
|Purpose||Personal information used||Lawful basis|
|We want to keep you informed of the progress of your application during the engagement process. Your contact details We need this information to be able to perform and administer the Agency application and engagement process||Your contact details||We need this information to be able to perform and administer the Agency application and engagement process|
|We need to assess your skills and experience and to make decisions about your suitability for operating an Agency role with Morses Club.||Your personal information including criminal records and credit history information.||We have a legitimate interest to run and manage our business |
We have a legal obligation to ensure that we have identified and assessed potential risks if we engage someone with a criminal record.
Processing of special category information such as criminal records and credit history is only undertaken with your consent; however you should be aware that if you do not give your consent, or if you later withdraw your consent to us processing this information, we may not be able to offer you the Agency role with us, or to confirm an offer made earlier in the process.
|We need to comply with health and safety obligations||Your personal contact information; records of the date / times you attended our premises during the engagement process;||We have a legal obligation to comply with Health and Safety laws|
|To deal with incidents and accidents on our premises involving you, or other agents, employees, workers, directors, consultants and contractors, that may arise during the engagement process||All your personal information including ‘special categories’ of personal information||We have a legitimate interest to ensure that all legal and personal injury claims are managed effectively.|
|We’d like to keep you informed of vacant Agencies , if there were none available when you initially enquired and where you would like us to do so||All of the personal information we collect about you (excluding criminal records and credit history) information||We have a legitimate interest to run and manage our business|
|To keep appropriate records of applications for our Agency engagement process||All personal information; special categories of information; criminal records and credit history checks|| We also have a legitimate interest to keep proper records |
We process criminal records, credit history on the basis of legal obligations or based on your explicit consent
|For the purpose of complying with any regulatory requirements||All the personal information ; special categories of information; criminal records and credit history checks|| We may have a legal obligation to comply with regulatory requirements and we have a legitimate interest in complying with regulatory requirements |
We process criminal records, credit history on the basis of legal obligations or based on your explicit consent
|We will use and retain information about criminal convictions to comply with law and in order to determine your eligibility to operate an Agency with us||Information about your criminal convictions and offences (including driving offences)||We process this on the basis of legal obligations and your explicit consent.|
Who we share your personal information with
During our Agency application and selection process your information may be shared with:
- The Government or our regulators where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office (ICO) or the Financial Conduct Authority (FCA);
- Our professional legal, accountancy and other advisors and auditors based in the United Kingdom in order to obtain legal, accountancy and other professional advice;
- Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
- Our IT service providers based in the United Kingdom and India that provide network and storage infrastructure and/or software programs and support to us in connection with the operation of our business.
We do not disclose your personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell your data.
Please note that the contractual arrangements we have in place with all of our third-party service providers require them to take appropriate security measures to protect your personal information.
Transferring your personal information internationally
During your application we will not transfer your data out of the European Economic Area (EEA) or to any country that has been deemed (by the Information Commissioners Office) to have inadequate data protection controls.
How long we keep personal information for
We will keep your application records for 12 months from the date you applied, if you are waiting for an Agency to become available. If we are unable to offer you an Agency your records will be kept for 4 weeks from the date advised you of this.
Your rights in relation to personal information
You have the following rights in relation to your personal information:
- to be informed about how your personal information is being used;
- to access the personal information we hold about you;
- to request the correction of inaccurate personal information we hold about you;
- to request the erasure of your personal information in certain limited circumstances;
- to restrict processing of your personal information where certain requirements are met;
- to object to the processing of your personal information;
- to request that we transfer elements of your data either to you or another service provider; and
- to object to certain automated decision making processes using your personal information.
Some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as there are specific requirements and exemptions which apply to these rights (however some have no conditions attached for example, your right to withdraw consent or object to processing for direct marketing are absolute rights).
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us, using the details set out in the “Contacting us” sections below.
Please note that we may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office, however we are here to help and encourage you to contact us to resolve your complaint first.
Changes to this notice
We regularly review the ways in which we use personal information during our Agent engagement processes and this means that we may update this privacy notice from time to time. If we change this notice in a material way, we will place an announcement at the top of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so.
If you would like more information about any part of this privacy notice, or you have a query or complaint in connection with the information we hold about you, please email firstname.lastname@example.org or write to Data Protection Officer, Kingston House, Centre 27 Business Park, Woodhead Road, Birstall, WF17 9TD.