Privacy Notice This Privacy Notice sets out the basis on which Paid Today Ltd will process personal information provided to us, this information is also referred to as ‘personal data’. We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you. Our core business activity is payroll. For the purposes of this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as ‘Payroll Services’. Our company Data Protection Officer can be contacted at payroll@paid-today.co.uk or by telephone: 020 3892 8080. If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us, Please refer to Section 4 ’Your rights‘, in respect of data that we already hold, or which we receive from third parties.

Section 1: This section applies to individuals wishing to use or using our Payroll Services: The personal data we collect or receive includes the following as applicable: • Name • Address • Email and other contact details • Date of birth • Job history (including information relating to placements through us) • Bank details • National insurance and tax (payroll) information We may obtain your personal data from the following sources (please note that this list is not exhaustive): • You (e.g. an application or registration form) • Our websites and software applications Where you are a Candidate and we have obtained your personal data from a third party, it is our policy to advise you of the source when we first communicate with you. How we will use your personal data: The processing of your personal information may include: • Collecting and storing your personal data, whether in manual or electronic files • Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers • Retaining a record of our dealings • Establishing quality, training and compliance with our obligations and best practice • For the purposes of backing up information on our computer systems Why we process your personal data: 1. Entering into and performing a contract with you: In order to provide our Payroll Services we may enter into a contract with you and/or a third party. In order to enter into a contract we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations. For example, in order to process payroll, a national insurance number and bank details will be required. 2. Compliance with legal obligations (regulatory and statutory obligations): We must comply with a number of statutory provisions when providing our Payroll Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things require us to: • Verify your identity • Maintain records for specific periods 

Where we engage a person to work for us (whether directly or as supplied to a Client), there are other statutory obligations that must be complied with including payroll, tax, social security, HMRC reporting requirements, and any other law or regulation. We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioner’s Office. 3. Our legitimate interests (carrying on the commercial activity of Payroll Services): In providing our Payroll Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include: • Retaining records of our dealings and transactions and where applicable, use such records for the purpose of: • establishing compliance with contractual obligations • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims • protecting our reputation • maintaining a back up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach • evaluating quality and compliance including compliance with this Privacy Notice • determining staff training and system requirements • Using your personal data to: • assess suitability and contact you regarding our services This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes. 4. Consent to our processing of your data: We may process your personal data on the basis that you have consented to us doing so for the specific purpose of our payroll service. You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal. Who we share personal data with: We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include: • Individuals, hirers and other third parties necessary for the provision of our Payroll Services • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us • Parties who process data on our behalf, which may include • IT support
• storage service providers including cloud • Legal and professional advisers • Insurers
 Section 2: This section applies where you are an individual working for a third party with whom we have dealings. For example, a client or a payroll company. We may collect your personal data in the course of our dealings and this may include the following: • Your contact information, which may include your full name, job role, contact telephone number and email How we will use your personal data: We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Payroll Services. Processing may include: • Collecting and storing your personal data, whether in manual or electronic files • Using the data to communicate with you • Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Payroll Services • Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for • Collating market or sector specific information and providing the same to our clients • Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers • Retaining records of our dealings with you and the organisation whom you represent • Establishing quality, training and compliance with our obligations and best practice Why we process your personal data: 1. Compliance with legal obligations (regulatory and statutory obligations) We must comply with a number of statutory provisions when providing our Payroll Services, which necessitate the processing of personal data. We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC. 2. Our legitimate interests (carrying on the commercial activity of Payroll Services): In providing our Payroll Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include: • Using your personal data: • to contact you regarding our Payroll Services • as otherwise necessary to provide our Payroll Services and/or to meet our obligations • to personalise your experience and our offering, whether via our website or otherwise • Retaining records of our dealings and transactions and where applicable, use such records for the purpose of: • establishing compliance with contractual obligations • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims • protecting our reputation • maintaining a back up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach • evaluating quality and compliance including compliance with this Privacy Notice • determining staff training and system requirements For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes. 3. Consent: We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal. Sensitive Personal Data (SPD) Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Payroll Services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health. Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Payroll Services. This will be for one or more of the following reasons: • You have explicitly consented to the processing • Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law • To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims Who we share personal data with: We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include: • Information necessary for the provision of our Payroll Services • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us • Parties who process data on our behalf, which may include: • IT support • storage service providers including cloud • Legal and professional advisers • Insurers Section 3: This section applies to all personal data Transfer of data to other jurisdictions: In the course of the provision of our Payroll Services we may transfer data to countries or international organisations outside of the EEA. Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place. Details relating to specific countries or organisations are available on request from the Data Protection Officer. If you do not wish to provide us with necessary data: There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Payroll Services. If you do not wish to provide us with information we request then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Payroll Service and in some cases may result in a breach of the contract we have with you or a third party you represent. Group companies and transfer: Although this Privacy Notice applies to us your data may be accessible to, and shared with other organisations within our group including Total Assist Recruitment Ltd and/or Total Assist Education Ltd for any of the purposes set out within this Privacy Notice, or where we have shared administration systems and staff. In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice. Data Security and Confidentiality: It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice. Cookies: A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website, which enables the website to tailor its offerings to your preferences when you visit it. We use cookies in the following ways: • Keep track of the number of times a visitor has been to the site and the activity carried out • Gather website statistics and track conversion rates • Measure the number and behaviours of Google Map users • Tracking by Google i.e. track certain websites that use Google plug-ins • Simple message that applies to submitted forms i.e. if an enquiry form is completed incorrectly, a message will be stored and presented to the user to indicate the errors in the submission, or if a form is submitted successfully, a message is stored and presented to the user thanking them for their enquiry Retaining your data: In most circumstances your data will not be retained for more than seven (7) years from the last point at which we provided any services or otherwise engaged with you. It is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a seven (7) year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example, where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period. If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons. Please see Section 4 ‘Your Rights’ below. Changes to this Privacy Notice: This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you of the same. Section 4: Your rights We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to: • Request a copy of the personal data that we hold • Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data • Request that we restrict processing of your data in certain circumstances • Request that data is erased where the continued use of that data cannot be justified • Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process • Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations • Request that inaccurate or incomplete data is rectified • Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract • Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source. If you have any questions concerning your rights or should you wish to exercise any of these rights please contact our company Data Protection Officer at payroll@paid-today.co.uk or by telephone: 020 3892 8080. Complaints If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to the Data Protection Officer. This does not affect your right to make a complaint to the Information Commissioner’s Office.

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