Who are Gemba Advantage?
Gemba Advantage Limited (“GA”, “we”, “our”, “us”) is a software engineering company registered in England and Wales with company number 11682283.
Our registered office is 20-22 Wenlock Road, London, N1 7GU.
This privacy policy sets out how Gemba Advantage uses and protects any information that you give us when you use this website or by any other means.
Gemba Advantage is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, or by any other means, then you can be assured that it will only be used in accordance with this privacy notice.
Gemba Advantage may change this policy from time to time by updating this notice on the website. You should check the website from time to time to ensure that you are happy with any changes. Where there are substantial changes that will affect your rights, they will be provided to you as far as is reasonably practicable. This policy is effective from December 2019.
What is this notice for?
This policy is intended to provide information about how Gemba Advantage will use (or "process") personal data about individuals including: current and prospective staff; current and prospective customers.
This information is provided in accordance with the rights of individuals under General Data Protection Regulation (GDPR) to understand how their data is used.
This Privacy Notice applies alongside any other information Gemba Advantage may provide about a particular use of personal data, for example when collecting data via an online or paper form.
Responsibility for data protection
We will always process the Personal Data you provide in a manner compliant with the EU’s GDPR and all other legislation applicable to our business in the jurisdictions in which we operate. We will strive to keep your information accurate and up to date, and not keep it for longer than is necessary. Your Personal Data will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle. It is the responsibility of our Data Protection Officer (DPO) to ensure Gemba Advantage is compliant with current legislation.
Our DPO is David Mann and can be contacted by emailing dpo@gembaadvantage.com.
Why we need to process personal data
Under the EU’s GDPR Personal Data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.
Types of personal data that we process
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Recruitment Data includes information about job applicants.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How we collect data
We collect and process some or all of the following types of information from you:
Information that you provide by filling in forms on the Gemba Advantage website (“Website”). This includes information provided at the time of registering to use the Website, subscribing to our Services, posting material or requesting further information or services. We may also ask you for information when you report a problem with the Website.
If you contact Us, We may keep a record of that correspondence.
If you apply for a job with Us, We will process the Personal Data you have shared for recruitment purposes only.
We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
Details of all actions that you carry out through the Website and of the provision of services to you.
Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to our site and the resources that you access.
Who has access to personal data and who we share it with
As part of your employment, We will collect and store Personal Data about you. This information will be accessible to you while employed, and includes but is not limited to: proof of your identity, contact details, financial information for payroll and benefits, and contact information for your references.
With your agreement, we will share only the necessary Personal Data with our benefits providers to enrol you into any benefit schemes. This includes our Group Pension Scheme, Group Life Scheme, Childcare Vouchers and Cycle Scheme, all of which are managed by third parties independently responsible for your data.
On termination of your employment, Gemba Advantage will remove your immediate access to the information stored about you (as part of removing your access to our IT systems), but will continue to store this information in our archives. You have rights to this data and can request action to be taken by us.
We may share any relevant information to enable any investigation or process connected to or requested by law or law enforcement.
How long we keep personal data
Gemba Advantage will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason.
Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as set out below. This right may be exercised by emailing us at dpo@gembaadvantage.com.
Request access to your personal data;
Request correction of your personal data;
Request erasure of your personal data;
Object to processing of your personal data;
Request restriction of processing your personal data;
Request transfer of your personal data; and
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us as outlined above.
Data Accuracy and security
Gemba Advantage will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify Us of any changes to information held about them.
An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected (subject to certain exemptions and limitations under Act): please see above.
We will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to systems. All staff will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Queries and complaints
Any comments or queries on this policy should be directed to our Data Protection Officer at dpo@gembaadvantage.com and we will respond
If an individual believes that We have not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should make a referral to or lodge a complaint with the Information Commissioner’s Office, by visiting the following website: https://ico.org.uk/make-a-complaint/
Job Applicant Privacy Notice
Our Data Controller is David Mann and can be contacted by emailing dpo@gembaadvantage.com.
Introduction
During the recruitment process, Gemba Advantage Ltd (the Company) collects and processes personal data relating to job applicants.
The Company is committed to being clear and transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the Company collect and process?
The Company collects and processes a range of personal information (personal data) about you. Personal data means any information about an individual from which the person can be identified. This includes:
Personal contact details, such as your name, title, address and contact details, including email address and telephone number;
details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers;
information about your remuneration, including entitlement to benefits such as pensions;
information about your entitlement to work in the UK; and
equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
The Company collects this information in a variety of ways during the application and recruitment process. For example, data may be contained in application forms and CVs, obtained from identity documents, such as your passport and collected through interviews and assessment tests.
In some cases, the Company collects personal data about you from third parties, such as references supplied by former employers.
Data is stored in a range of different places, including on your application record, in the Company's HR management systems and in other IT systems including the Company's email system.
Why does the Company process personal data?
The Company needs to process data prior to entering into a contract with you. We also need to process data to enter into an employment contract with you and to meet our obligations under that employment contract.
In addition, the Company needs to process data to ensure that we are complying with our legal obligations. For example, we are required to check an employee's entitlement to work in the UK before employment begins.
The Company has a legitimate interest in processing personal data during the recruitment process and in keeping records of that process. Processing such data from job applicants enables the Company to manage the recruitment process, assess the suitability of candidates and make informed decision as to whom we wish to recruit. The Company may also have to process data from job applicants in order to defend legal claims.
The Company processes health information if we need to make reasonable adjustments to the recruitment process for candidates with a disability.
If you fail to provide personal information
You are under no obligation to provide the Company with data during the recruitment process. However, if you do not prove certain information when requested, the Company may not be able to process your application for employment properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for you if this information is not provided.
Automated decision-making
Our employment decisions are not based solely on automated decision-making.
For how long do you keep data?
The Company will only hold your personal data for as long as is necessary to fulfil the purposes for which we collected it. If your application for employment is unsuccessful, the Company will hold your data on file for 6 months after the end of the recruitment process. At the end of that period, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and we shall issue a new privacy notice which sets down the periods for which your data will be held.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment process, including with the management team.
The Company will not share your data with third parties unless we make you an offer of employment. In those circumstances, the Company shall share your data with third parties where required by law and where it is necessary in order to administer the working relationship with you or where we have another legitimate interest in doing so. The Company will then share your data with former employers to obtain references for you.
The Company will not transfer your data to countries outside the European Economic Area.
How does the Company protect data?
The Company takes the security of your data seriously. The Company has internal policies and controls in place to prevent your data being lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
Your rights
As a data subject, you have a number of rights. You can:
access and obtain a copy of your data on request (known as a “data subject access request”);
require the Company to change incorrect or incomplete data;
request erasure of your personal information. This enables you to ask the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing; and
ask the Company to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.
If you would like to exercise any of these rights, or you have any questions about the privacy notice, please contact the Data Controller.
If you believe that the Company has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office.