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Legal Proforma

Modern Day Slavery Policy

The Modern Slavery Act 2015 (MSA 2015) consolidates offences relating to trafficking and slavery. In compliance with our obligations under the MSA please see below our Modern Slavery Act Policy that details the steps we have taken as a company to ensure that slavery and human trafficking is not taking place in any of our supply chains, and in any part of our business.

More information on the Act can be found at: www.legislation.gov.uk

1. POLICY STATEMENT

1.1 It is our strict policy to conduct all of our business in an honest and ethical manner and we take a zero-tolerance approach to modern slavery whether under UK law or under the law of any foreign country.

1.2 We are committed to acting ethically, fairly, professionally and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.3 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

1.4 Modern slavery is a crime and a violation of fundamental human rights.

1.5 We will uphold all laws relevant to modern slavery and corruption, including the Modern Slavery Act 2015.

1.6 Unless otherwise stated, the interpretation and application of this policy applies to any modern slavery activity in the UK and any foreign company.

2. ABOUT THIS POLICY

2.1 The purpose of this policy is to:

(a) set-out our responsibilities, and of those working for us and any third party, in observing and upholding our position on modern slavery;

(b) ensure that any introducers of new employees are not in breach of this policy; and

(b) provide information and guidance to those working for us and any third party on how to recognise and deal with modern slavery issues.

2.2 If we fail to prevent those working for us and any third party facilitating modern slavery, we can face criminal sanctions including an unlimited fine, as well as exclusion from public contracts, damage to our reputation and individuals can be imprisoned. We therefore take our legal responsibilities seriously.

2.3 We have identified that the following are particular risks for our business:

(a) an introducer or potential introducer of new employees offers to source foreign candidates that do not have legal work permits;

(b) when we do not interview candidates face-to-face to work away from our main place of business; or

(c) we may be provided with fraudulent identification documents for candidates.

2.4 To address those risks we have taken the following steps:

(a) our internal policies specifically prohibit the above;

(b) our internal training processes specifically prohibit the above;

(c) we undertake thorough due diligence identity and right-to-work checks and auditing is undertaken by our compliance manager

2.5 In this policy, third party means any individual or organisation you or we come into contact with during the course of our business, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisers, representatives and officials, politicians and political parties.

2.6 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

3. WHO MUST COMPLY WITH THIS POLICY?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.

4. WHO IS RESPONSIBLE FOR THE POLICY

4.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2 The compliance manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

4.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

4.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.

4.5 This policy will be reviewed by the board at least on an annual basis to ensure it fully complies with our ethical and legal duties and is fit for purpose.

5. WHAT IS MODERN SLAVERY

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

6. WHAT YOU MUST NOT DO

6.1 It is not acceptable for you (or someone on your behalf) to:

(a) engage in any form of facilitating modern slavery;

(b) aid, abet, counsel or procure the commission of a modern slavery offence by another person;

(c) fail to promptly report any request or demand from any third party to facilitate modern slavery, or any suspected modern slavery by another person;

(d) engage in any other activity that might lead to a breach of this policy; or

(e) threaten or retaliate against another individual who has refused to commit a modern slavery offence or who has raised concerns under this policy.

7. YOUR RESPONSIBILITIES

7.1 You must ensure that you read, understand and comply with this policy.

7.2 The prevention, detection and reporting of modern slavery are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

7.3 You must notify the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if an employee or third party asks or in any way indicates that they want us to employ a potential victim of modern slavery.

8. HOW TO RAISE A CONCERN

8.1 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage with the compliance manager.

8.2 If you become aware of or suspect modern slavery, with the welfare and safety of potential or actual victims as a priority, you must notify the compliance manager as soon as possible.

8.3 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the compliance manager as soon as possible.

9. PROTECTION

9.1 Individuals who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

9.2 We are committed to ensuring no one suffers any detrimental treatment as a result of:

(a) refusing to take part in, be concerned in, or facilitate modern slavery activity by another person;

(b) refusing to aid, abet, counsel or procure the commission of a modern slavery offence; or

(c) reporting in good faith their suspicion that an actual or potential modern slavery offence has taken place or may take place in the future.

9.3 Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure within the Staff Handbook.

10. TRAINING AND COMMUNICATION

10.1 Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

10.2 We will ensure that mandatory training on this policy is offered to those employees, workers and associated persons who have been identified as being at risk of exposure to modern slavery activity, at least once every year.

10.3 Our zero-tolerance approach to modern slavery activity must be communicated to all third parties at the outset of our business relationship with them and as appropriate after that.

11. BREACHES OF THIS POLICY

11.1 Breaches of this policy by employees will result in disciplinary action under our Disciplinary Rules and Procedure within the Staff Handbook.

11.2 We may terminate our relationship with third parties working on our behalf if they breach this policy.

Anti Bribery and Corruption Policy

1. What does your policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of Habit Hire and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for Habit Hire It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1 Habit Hire is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. Habit Hire has zero-tolerance for bribery and corrupt activities. We are committed to acting
professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2 Habit Hire will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

2.3 Habit Hire recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK).

3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum.

4. Definition of bribery

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.

5. What is and what is NOT acceptable

5.1 This section of the policy refers to 4 areas:

• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.

5.2 Gifts and hospitality

Habit Hire accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

b. It is not made with the suggestion that a return favour is expected.

c. It is in compliance with local law.

d. It is given in the name of the company, not in an individual’s name.

e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).

g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.

h. It is given/received openly, not secretly.

i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.

j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).

k. It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.

5.4 Habit Hire recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.

5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.

5.7 Facilitation Payments and Kickbacks – Habit Hire does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

5.8 Habit Hire does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

5.9 Habit Hire recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

a. Keep any amount to the minimum.

b. Ask for a receipt, detailing the amount and reason for the payment.

c. Create a record concerning the payment.

d. Report this incident to your line manager.

5.10 Political Contributions

Habit Hire will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

5.11 Charitable Contributions – Habit Hire accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.

6. Employee Responsibilities

6.1 As an employee of Habit Hire, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti bribery and corruption information you are given.

6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. [A Managing Director has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

7.1 This section of the policy covers 3 areas:

a. How to raise a concern.

b. What to do if you are a victim of bribery or corruption.

c. Protection.

7.2 How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Habit Hire, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.

7.3 Habit Hire will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

7.4 What to do if you are a victim of bribery or corruption – You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

7.5 Protection – If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Habit Hire understands that you may feel worried about potential repercussions. Habit Hire will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

7.6 Habit Hire will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.

8. Training and communication

8.1 Habit Hire will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

8.2 Habit Hire’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

8.3 Habit Hire will provide relevant antibribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with antibribery training where there is a potential risk of facing bribery or corruption during work activities.

9. Record keeping

9.1 Habit Hire will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

10.1 Habit Hire compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.

10.4 This policy does not form part of an employee’s contract of employment and Habit Hire may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

 

Privacy Policy

Who we are

Our website address is: http://habithire.com

The information we collect

We collect information about you from different places including:

  • directly from you
  • from a third party acting on your behalf e.g. an intermediary or broker
  • when we generate it ourselves
  • from other organisations

We’ll only collect your information in line with relevant regulations and law and this may relate to any of our products or services you apply for, currently hold or have held in the past.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services.

We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services. We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

Your rights

You have a number of rights relating to your information, including but not limited to:

  • to request a copy of the data we hold for you
  • to ask us to share it with another party
  • to ask us to update incorrect or incomplete details
  • to object to or restrict processing of it
  • to opt-out of us using it
  • to ask us to delete it
  • to make a complaint
Equal Opportunities & Diversity Policy

Who we are

Our website address is: http://habithire.com

The information we collect

We collect information about you from different places including:

  • directly from you
  • from a third party acting on your behalf e.g. an intermediary or broker
  • when we generate it ourselves
  • from other organisations

We’ll only collect your information in line with relevant regulations and law and this may relate to any of our products or services you apply for, currently hold or have held in the past.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services.

We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services. We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

Your rights

You have a number of rights relating to your information, including but not limited to:

  • to request a copy of the data we hold for you
  • to ask us to share it with another party
  • to ask us to update incorrect or incomplete details
  • to object to or restrict processing of it
  • to opt-out of us using it
  • to ask us to delete it
  • to make a complaint
Complaints Policy

Who we are

Our website address is: http://habithire.com

The information we collect

We collect information about you from different places including:

  • directly from you
  • from a third party acting on your behalf e.g. an intermediary or broker
  • when we generate it ourselves
  • from other organisations

We’ll only collect your information in line with relevant regulations and law and this may relate to any of our products or services you apply for, currently hold or have held in the past.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services.

We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services. We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

Your rights

You have a number of rights relating to your information, including but not limited to:

  • to request a copy of the data we hold for you
  • to ask us to share it with another party
  • to ask us to update incorrect or incomplete details
  • to object to or restrict processing of it
  • to opt-out of us using it
  • to ask us to delete it
  • to make a complaint

Legal Proforma

Modern Day Slavery Policy

The Modern Slavery Act 2015 (MSA 2015) consolidates offences relating to trafficking and slavery. In compliance with our obligations under the MSA please see below our Modern Slavery Act Policy that details the steps we have taken as a company to ensure that slavery and human trafficking is not taking place in any of our supply chains, and in any part of our business.

More information on the Act can be found at: www.legislation.gov.uk

1. POLICY STATEMENT

1.1 It is our strict policy to conduct all of our business in an honest and ethical manner and we take a zero-tolerance approach to modern slavery whether under UK law or under the law of any foreign country.

1.2 We are committed to acting ethically, fairly, professionally and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.3 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

1.4 Modern slavery is a crime and a violation of fundamental human rights.

1.5 We will uphold all laws relevant to modern slavery and corruption, including the Modern Slavery Act 2015.

1.6 Unless otherwise stated, the interpretation and application of this policy applies to any modern slavery activity in the UK and any foreign company.

2. ABOUT THIS POLICY

2.1 The purpose of this policy is to:

(a) set-out our responsibilities, and of those working for us and any third party, in observing and upholding our position on modern slavery;

(b) ensure that any introducers of new employees are not in breach of this policy; and

(b) provide information and guidance to those working for us and any third party on how to recognise and deal with modern slavery issues.

2.2 If we fail to prevent those working for us and any third party facilitating modern slavery, we can face criminal sanctions including an unlimited fine, as well as exclusion from public contracts, damage to our reputation and individuals can be imprisoned. We therefore take our legal responsibilities seriously.

2.3 We have identified that the following are particular risks for our business:

(a) an introducer or potential introducer of new employees offers to source foreign candidates that do not have legal work permits;

(b) when we do not interview candidates face-to-face to work away from our main place of business; or

(c) we may be provided with fraudulent identification documents for candidates.

2.4 To address those risks we have taken the following steps:

(a) our internal policies specifically prohibit the above;

(b) our internal training processes specifically prohibit the above;

(c) we undertake thorough due diligence identity and right-to-work checks and auditing is undertaken by our compliance manager

2.5 In this policy, third party means any individual or organisation you or we come into contact with during the course of our business, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisers, representatives and officials, politicians and political parties.

2.6 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

3. WHO MUST COMPLY WITH THIS POLICY?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.

4. WHO IS RESPONSIBLE FOR THE POLICY

4.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2 The compliance manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

4.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

4.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.

4.5 This policy will be reviewed by the board at least on an annual basis to ensure it fully complies with our ethical and legal duties and is fit for purpose.

5. WHAT IS MODERN SLAVERY

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

6. WHAT YOU MUST NOT DO

6.1 It is not acceptable for you (or someone on your behalf) to:

(a) engage in any form of facilitating modern slavery;

(b) aid, abet, counsel or procure the commission of a modern slavery offence by another person;

(c) fail to promptly report any request or demand from any third party to facilitate modern slavery, or any suspected modern slavery by another person;

(d) engage in any other activity that might lead to a breach of this policy; or

(e) threaten or retaliate against another individual who has refused to commit a modern slavery offence or who has raised concerns under this policy.

7. YOUR RESPONSIBILITIES

7.1 You must ensure that you read, understand and comply with this policy.

7.2 The prevention, detection and reporting of modern slavery are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

7.3 You must notify the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if an employee or third party asks or in any way indicates that they want us to employ a potential victim of modern slavery.

8. HOW TO RAISE A CONCERN

8.1 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage with the compliance manager.

8.2 If you become aware of or suspect modern slavery, with the welfare and safety of potential or actual victims as a priority, you must notify the compliance manager as soon as possible.

8.3 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the compliance manager as soon as possible.

9. PROTECTION

9.1 Individuals who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

9.2 We are committed to ensuring no one suffers any detrimental treatment as a result of:

(a) refusing to take part in, be concerned in, or facilitate modern slavery activity by another person;

(b) refusing to aid, abet, counsel or procure the commission of a modern slavery offence; or

(c) reporting in good faith their suspicion that an actual or potential modern slavery offence has taken place or may take place in the future.

9.3 Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure within the Staff Handbook.

10. TRAINING AND COMMUNICATION

10.1 Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

10.2 We will ensure that mandatory training on this policy is offered to those employees, workers and associated persons who have been identified as being at risk of exposure to modern slavery activity, at least once every year.

10.3 Our zero-tolerance approach to modern slavery activity must be communicated to all third parties at the outset of our business relationship with them and as appropriate after that.

11. BREACHES OF THIS POLICY

11.1 Breaches of this policy by employees will result in disciplinary action under our Disciplinary Rules and Procedure within the Staff Handbook.

11.2 We may terminate our relationship with third parties working on our behalf if they breach this policy.

Anti Bribery and Corruption Policy

1. What does your policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of Habit Hire and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for Habit Hire It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1 Habit Hire is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. Habit Hire has zero-tolerance for bribery and corrupt activities. We are committed to acting
professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2 Habit Hire will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

2.3 Habit Hire recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK).

3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum.

4. Definition of bribery

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.

5. What is and what is NOT acceptable

5.1 This section of the policy refers to 4 areas:

• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.

5.2 Gifts and hospitality

Habit Hire accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

b. It is not made with the suggestion that a return favour is expected.

c. It is in compliance with local law.

d. It is given in the name of the company, not in an individual’s name.

e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).

g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.

h. It is given/received openly, not secretly.

i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.

j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).

k. It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.

5.4 Habit Hire recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.

5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.

5.7 Facilitation Payments and Kickbacks – Habit Hire does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

5.8 Habit Hire does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

5.9 Habit Hire recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

a. Keep any amount to the minimum.

b. Ask for a receipt, detailing the amount and reason for the payment.

c. Create a record concerning the payment.

d. Report this incident to your line manager.

5.10 Political Contributions

Habit Hire will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

5.11 Charitable Contributions – Habit Hire accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.

6. Employee Responsibilities

6.1 As an employee of Habit Hire, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti bribery and corruption information you are given.

6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. [A Managing Director has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

7.1 This section of the policy covers 3 areas:

a. How to raise a concern.

b. What to do if you are a victim of bribery or corruption.

c. Protection.

7.2 How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Habit Hire, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.

7.3 Habit Hire will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

7.4 What to do if you are a victim of bribery or corruption – You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

7.5 Protection – If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Habit Hire understands that you may feel worried about potential repercussions. Habit Hire will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

7.6 Habit Hire will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.

8. Training and communication

8.1 Habit Hire will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

8.2 Habit Hire’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

8.3 Habit Hire will provide relevant antibribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with antibribery training where there is a potential risk of facing bribery or corruption during work activities.

9. Record keeping

9.1 Habit Hire will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

10.1 Habit Hire compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.

10.4 This policy does not form part of an employee’s contract of employment and Habit Hire may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

 

Privacy Policy

Who we are

Our website address is: http://habithire.com

The information we collect

We collect information about you from different places including:

  • directly from you
  • from a third party acting on your behalf e.g. an intermediary or broker
  • when we generate it ourselves
  • from other organisations

We’ll only collect your information in line with relevant regulations and law and this may relate to any of our products or services you apply for, currently hold or have held in the past.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services.

We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services. We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

Your rights

You have a number of rights relating to your information, including but not limited to:

  • to request a copy of the data we hold for you
  • to ask us to share it with another party
  • to ask us to update incorrect or incomplete details
  • to object to or restrict processing of it
  • to opt-out of us using it
  • to ask us to delete it
  • to make a complaint
Equal Opportunities & Diversity Policy

Who we are

Our website address is: http://habithire.com

The information we collect

We collect information about you from different places including:

  • directly from you
  • from a third party acting on your behalf e.g. an intermediary or broker
  • when we generate it ourselves
  • from other organisations

We’ll only collect your information in line with relevant regulations and law and this may relate to any of our products or services you apply for, currently hold or have held in the past.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services.

We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services. We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

Your rights

You have a number of rights relating to your information, including but not limited to:

  • to request a copy of the data we hold for you
  • to ask us to share it with another party
  • to ask us to update incorrect or incomplete details
  • to object to or restrict processing of it
  • to opt-out of us using it
  • to ask us to delete it
  • to make a complaint
Complaints Policy

Who we are

Our website address is: http://habithire.com

The information we collect

We collect information about you from different places including:

  • directly from you
  • from a third party acting on your behalf e.g. an intermediary or broker
  • when we generate it ourselves
  • from other organisations

We’ll only collect your information in line with relevant regulations and law and this may relate to any of our products or services you apply for, currently hold or have held in the past.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services.

We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

How we’ll use your information

We’ll use it to provide any products and services you’ve requested and other purposes, for example:

  • to confirm your identity and address
  • to understand how you use our services
  • to carry out our services
  • to improve our products and services
  • to offer you other services we believe may
  • benefit you unless you ask us not to

We’ll only use your information where we’re allowed to by law e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

We may use automated systems to help us verify your identity, and carry out fraud and money laundering checks.

Who we can share your information with

We may share your information with any subcontractors, agents, or service providers who work for us to help us deliver our services. We may also share your information with other organisations, for example regulators, insurers, other financial institutions, brokers and agents, as well as credit reference and fraud prevention agencies. When we do this, we will ensure that the organisation that we share your data with is fully GDPR compliant.

Your details will never be shared with any third party for any purpose other than that of carrying out the payroll umbrella service we already provide to you.

How long we’ll keep your information

We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

All data we hold for you will be completely deleted 7 years after the termination of our arrangement with you. You have the right to request the deletion of your data at any time.

Your rights

You have a number of rights relating to your information, including but not limited to:

  • to request a copy of the data we hold for you
  • to ask us to share it with another party
  • to ask us to update incorrect or incomplete details
  • to object to or restrict processing of it
  • to opt-out of us using it
  • to ask us to delete it
  • to make a complaint