HTA Data Privacy Policy

HTA Data Privacy Policy

Approval History
Revision

Revision DateAuthor

Reason0D118-Apr-2018

R. NaylorCreation

1D018-Apr-2018

R. NaylorFirst Issue

2D024-Mar-2021

R. Naylor

New Company Address; renamed to HTA Data
Privacy Policy.

3D009-Jan-2024

R. Naylor

Minor changes requested by HOR

4D012-Jan-2024

R. Naylor

Further changes requested by HOR

5D019-Jan-2024

R. Naylor

Further changes requested by HOR

6D009-Feb-2024

R. Naylor

Removed Company Confidentiality footer at HOR
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HTA Data Privacy Policy

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HTA Data Privacy Policy

Table of Contents
1

DATA PRIVACY POLICY ............................................................................. 5When printed, this document is for reference only. Please ensure you are using the correct version.
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HTA Data Privacy Policy

1DATA PRIVACY POLICY

It is the policy of Horiba Test Automation (HTA) that it shall at all times respect the privacy ofindividuals by processing personal data only for legitimate and lawful purposes and in strict
adherence to current data protection legislation. Set out below is our Data Privacy Policy whichmakes clear how we meet our obligations to everyone whose personal data we process and to theSupervising Authority under UK law.

The Data Protection Coordinator
The Data Protection Coordinator for Horiba Test Automation can be contacted at:
Horiba Test Automation
Brook Court
Whittington HallWhittington Road
Worcestershire
WR5 2RX+44 (0)1905 359359
Supervising Authority
The Supervising Authority for data privacy matters in the UK is the Information Commissioner’s
Office (ICO):
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
CheshireSK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Definitions‘Personal data’ means any information relating to an identified or identifiable natural person (‘datasubject’). An identifiable natural person is one who can be identified, directly or indirectly byreference to any other identifier.
‘Processing’ means any operation or set of operations which is performed on personal data or on
sets of personal data, whether or not by automated means.
‘Data Controller’ means the natural or legal person, public authority, agency or other body which,alone or jointly with others, determines the purposes and means of the processing of personal data.
‘Data Processor’ means a natural or legal person, public authority, agency or other body which
processes personal data on behalf of the controller.

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HTA Data Privacy Policy

Data Protection Principles
1. Data will be processed fairly, lawfully and in a transparent manner.
2. Data will be collected for specified, explicit and legitimate purposes.
3. Data will be adequate, relevant and limited to what is necessary.
4. Data will be accurate and kept up to date.
5. Data will be retained only for as long as necessary.
6. Data will processed in a manner to maintain security.
Lawful Basis for Processing
HTA will obtain, hold, use and disclose personal information for our legitimate business purposes, forthe fulfilment of legal obligations and as part of contractual arrangements. Processing of personal
data will include:• staff administration including occupational health, welfare and performance management• management of finance and accounts• training and personal development• property, asset and insurance management• vehicle and transport management• payroll and benefits management• management of complaints• management of information and communication technology systems• legal services• licensing and registration where applicable• pensions administration• procurement and contract management• health and safety management• performance of a business contract• obligations under the law to statutory authorities• business development and planning
The lawful basis for processing personal data is in all cases strictly in accordance with one or more of
the following:• the explicit consent of the individual• the performance of a contract (or for the purposes of entering in to a contract at the requestof the individual)• a legal obligation upon us e.g. tax affairs• in the vital interests of an individual• in the public interest or exercise of official authority• HTA’s legitimate business interests specifically to the extent that the Data Protection
Principles imposed by data protection legislation allow.
All personal information processed by us is done so fairly, lawfully and with appropriate justification.
We ensure that any personal information used by us or on our behalf is of the highest quality interms of accuracy, relevance, adequacy and limitation. It will be kept up-to-date, be protected
appropriately and securely destroyed when no longer required.

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HTA Data Privacy Policy

We will comply with all individuals' rights under existing data protection legislation.
Where personal data is held purely by virtue of the consent of the individual, that consent will be
explicitly given, recorded and may be withdrawn at any time without penalty.
Your Data Protection Rights
As the person to whom personal data relates, you have certain rights regarding how your data isheld, used, processed or shared by us. These are explained below:
••
•••

••

•

The right to be informed – You have the right to insist on transparency over how we useyour personal data and to be provided with ‘fair processing’ information.
The right of access – You have the right to access your personal data and any othersupplementary information within one month. You can request this free of charge.
The right to rectification – You are entitled to have data rectified if it is inaccurate orincomplete.
The right to erasure – You may request the deletion or removal of personal data if you
believe that there is no longer any lawful basis for which it is processed.
The right to restrict processing – You have the right to request restriction of the processingof your data if you contest its accuracy or object to its processing for any reason. In suchcases HTA is entitled to store your data but not further process it until an investigation iscomplete and your complaint is verified.
The right to data portability – You have the right to request your personal data be given to
you in a machine readable format to be used for your own purposes and to transfer it easily
from one IT environment to another. This only applies to information that you have given usand where the processing is carried out by automated means. We may not be able toprovide you with this information if it prejudices the rights of another person.
The right to object – You have the right to object to the processing of your data where theprocessing is based on the legitimate interests of HTA with regard to direct marketing or
where it is being used for statistical purposes.
The right to object to automated decision making and profiling – There is a right not to be
subject to a decision based solely on automated processing, including profiling (i.e. decisions
made without human intervention). This right does not apply however if the processing isnecessary for entering into, or performance of, a contract between you and HTA (e.g.
employment contract) or where the data is processed with your explicit consent.

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HTA Data Privacy Policy

Types of Personal Data Processed
In the legitimate course of our business we may obtain, hold, use and disclose personal information
relating to or consisting of any of the following:
••
••••
••••
•
•••••••

personal details such as name, address and biographical details
family and social circumstances
education and training details
employment details
professional qualifications and experiences
financial details
goods or services provided
physical or mental healthcriminal offences, outcomes and sentencessound and visual images
licenses or permits held
information relating to health and safetycomplaints and correspondence
incident and accident details
performance management information
copies of correspondence to or from us
data derived from IT systems such as IP addresses or location information
information that may be required for the performance of a contract

The source and origins of personal data that we hold, use or disclose
We may obtain personal information from a wide variety of sources, including the following:
••
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
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HM Revenue and Customs
law enforcement agencies and regulatory or licensing authorities
legal representatives
business partners who share a legitimate business contract with usprospective business partners
external auditorscentral or local government, government agencies and departments
emergency services
individuals themselves
relatives, guardians or other persons associated with the individual
current, past or prospective employers of the individual
healthcare, social and welfare practitioners
education, training establishments and examining bodies
business associates and professional advisors
employees and agents of HTA
suppliers and providers of goods or services
persons making an enquiry or complaint
financial organisations and advisors
credit reference agencies
survey and research organisations
trade, employer associations and professional bodies
data Processors working on behalf of HTA

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HTA Data Privacy Policy••

our parent organisation and its subsidiaries
recruitment agencies

Whose Personal Data do we Process?
We may obtain, use and disclose personal information relating to a wide variety of individuals
including the following:•••••••

staff including volunteers, contractors, agency staff including temporary and casual workers
suppliers
business partners
complainants, correspondents and enquirers
relatives and associates of the individual concerned
advisers, consultants and other professional experts
former and potential members of staff

We will only obtain, hold, use or disclose appropriate personal information necessary to fulfil aparticular purpose. Personal information could be held in computer format or in a paper record. It
can also include other types of electronically held information such as CCTV images or audio
recordings.
Retention of Personal Data
We keep personal data for as long as, but no longer than is necessary for the particular purposes forwhich it is held or for any period that might be required by law. Where there is no further
requirement to use, hold or store personal data and the law does not require us to do so, we shallremove it from our records and systems. Our retention of personal data is strictly on the basis of theclear and justifiable existence of a lawful basis for processing.
It is not possible in this policy to explicitly state how long personal data should be retained for as thiswill vary considerably depending on the type of data and the lawful basis for its processing. Theoverriding rule is that the ‘storage limitation’ Data Protection Principle will apply in all cases:“Data shall be kept in a form which permits identification of data subjects for no longer than isnecessary for the purposes for which the personal data are processed”
Where Personal Data is Held
Personal data relating to any individual may be held, used and processed on a number of systems
and in a variety of formats. Personal data will be held in machine readable format on computers,servers (whether ours or hosted by a business partner), on mobile devices or in paper files. Thesewill include:
••
•
•••
•
•
•

HR systems
finance systems
customer databases
recruitment systems
occupational health records
managers’ individual filing systems – electronic and hard copy
project management systems
emails and correspondence
software configuration and document management systems

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HTA Data Privacy Policy

Who We Share Information WithWe may disclose personal information to a wide variety of recipients in any part of the world,including those from who personal information is obtained. Disclosure of personal information will
be made strictly on the grounds of the following and with suitable controls in place:
••
•
•
•
•

the explicit consent of the individual
the performance of a contract
a legal obligation upon us
in the vital interests of an individual
the public interest or exercise of official authority
HTA’s legitimate business interests

Where processing is to be carried out on behalf of HTA by a third party organisation (known as theData Processor), HTA shall use only processors providing by means of contractual clauses sufficientguarantees regarding appropriate technical and organisational measures that processing will meetthe requirements of the law and ensure the protection of the rights of the data subject. The
processor shall not engage another processor without the prior specific written authorisation ofHTA. We may share personal information with any of the following:••••••••
•
•
•
•
•
•
•
•
•
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law enforcement agencies and regulatory or licensing authorities
legal representatives
business partners who share a legitimate business contract with usprospective business partners
external auditors
central or local government, government agencies and departments
emergency services
current, past or prospective employers of the individual
healthcare, social and welfare practitioners
education, training establishments and examining bodies
business associates and professional advisors
managers within the Horiba Group of companies
suppliers and providers of goods or services
financial organisations and advisors
credit reference agencies
survey and research organisations
trade, employer associations and professional bodies
recruitment agencies

Overseas Transfers of Personal Data
HTA as part of its business operation will under certain conditions share personal data within theHoriba Group overseas and also to other overseas organisations. Some organisations that HTA
disclose personal information to are outside of the European Economic Area. We ensure that all
personal data shared with any overseas organisation is adequately protected.
All transfers of data overseas are governed strictly as follows:

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HTA Data Privacy Policy••••Within the Horiba Group – as allowed by a Framework Agreement.
Outside of the Horiba Group and outside of the EEA - by EC Model Data Protection Clauseagreements approved by the European Commission.
Within the EEA and to countries approved by the EC as having adequate data protection
standards – using standard contract with data privacy clauses.
With the US – Using EU/US Privacy Shield arrangements.

Automated Decision Making and Profiling
Automated decision making and profiling occurs where a computer system generates an output
relating to an individual without any human intervention, upon which a decision is made. HTA may
in limited circumstances use such systems. There is a right not to be subject to a decision based
solely on automated processing, including profiling (i.e. decisions made without humanintervention). This right does not apply however if the processing is necessary for entering into, orperformance of, a contract between you and HTA (e.g. employment contract) or where the data isprocessed with your explicit consent.
Data Security
HTA is committed to meeting the HORIBA Global IT Security policy.
Sensitive Personal Data
Previously ‘Sensitive Personal Data’ has now been designated as Special Category Data. Personal
data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union
membership, genetic data or biometric data for the purpose of uniquely identifying a person, data
concerning health or a person’s sex life or sexual orientation can only be processed under specificconditions.
All Special Category Data is held strictly on the basis of the consent of the data subject and isafforded the highest degree of protection.
Complaints or Queries
You have the right to make a complaint about the manner in which your personal data is stored,
used, processed or shared by us; or if you feel that any of your Data Protection Rights have been
violated.
You can direct all personal data queries or complaints to us by contacting
dataprotection.hta@horiba.com.
Or you can complain directly to the Information Commissioner’s Office (ICO) at
https://ico.org.uk/concerns/
You can also call the ICO Helpline on 0303 123 1113. The ICO is the UK's independent body set up touphold information rights.

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