Visitors to our website
When someone visits www.lustalux.co.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
We use a third party provider, Bespoke Internet to deliver our e-shots. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our content. For more information, please see Bespoke Internet privacy notice. Security and Performance. Lustalux Ltd uses a third party service to help maintain the security and performance of the Lustalux website. To deliver this service it processes the IP addresses of visitors to the Lustalux website
People who contact us via Social Media
All our Social Media activity is handled in house via the social media team.
If you send us a private or direct message via social media the message will be stored by Lustalux until it is actioned. It will not be shared with any other organisations.
People who email us
We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with the government. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant's identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person's record is in dispute. If a complainant doesn't want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the 'need to know' principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not, identify any complainants unless the details have already been made public.
People who Lustalux Ltd services
Lustalux Ltd offers various services to the public. We use a third party to deal with some publication requests, but they are only allowed to use the information to send out the publications.
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a publication to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.
People who register (notify) under the Data Protection Act 1998 Many businesses are required by law to 'notify' certain specified information to the Information Commissioner. This may contain personal information, for example where the business is a sole trader. Lustalux Ltd compiles this information into a register which it is required by law to make publicly available. Lustalux Ltd cannot therefore give any guarantees as to how the information contained on the register will be used by those accessing it.
When businesses fill in their registration forms, they are asked to provide the contact details of a relevant member of staff. Lustalux Ltd will use this for its own purposes, for example where we have a query about a registration, but will not put it on the public register.
When we request information as part of the registration process, we make it clear where the provision of information is required by law and where it is voluntary.
Job Applicants, current and former Lustalux Ltd employees
Lustalux Ltd is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at firstname.lastname@example.org.
What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You don't have to provide what we ask for but it might affect your application if you don't.
If you use our online application system, this will be collected by a data processor on our behalf (please see below).
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.
You will also be asked to provide equal opportunities for information. This is not mandatory information - if you don't provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
Some roles require a higher level of security clearance - this will be clear on the advert. If this is the case, then you will be asked to submit information via the National Security Vetting process to HMRC. HMRC will be the data controller for this information.
HMRC will tell us whether your application is successful or not. If it is unsuccessful, the Lustalux Ltd will not be told the reason(s) why but we might need to review your suitability for the role or how you perform your duties.
Our Code of Conduct requires all staff to declare if they have any potential conflicts of interest, or if they are active within a political party. If you complete a declaration, the information will be held on your personnel file.
Use of data processors
Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
If you use our online application system, you will provide the requested information to Vacancy Filler who provide this online service for us. Once you click 'apply now' you will be taken to Vacancy Filler's website and they will hold the information you submit but the ICO will have access to it.
Here is a link to their Privacy Notice. https://www.vacancy-filler.co.uk/privacy-policy/
For senior vacancies, we sometimes advertise through Local Recruitment Agencies. They will collect the application information and might ask you to complete a work preference questionnaire which is used to assess your suitability for the role you have applied for, the results of which are assessed by recruiters. You will need to check their Privacy policies for the way in which they collect and retain information following the end of our agreement.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.