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Varden Axis

                                                       Data Protection & Privacy Policy


 

 

 

1. WHAT IS THE PURPOSE OF THIS DOCUMENT?


Key points:
 

Varden Axis Ltd is committed to protecting the privacy and security of personal information.

This Data Protection Policy and Privacy Notice explains how we collect, use, store, and protect personal information during and after an individual’s working or commercial relationship with Varden Axis Ltd. This is in accordance with the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), which govern how personal data relating to UK and EU citizens must be handled.
 

These laws, and therefore this policy and privacy notice, apply to all current and former employees, workers, freelance contractors, consultants, and, where relevant, interns and volunteers.

The purpose of this document is to clearly explain our responsibilities in relation to personal data, what individuals can expect from us, and what we expect from anyone who comes into contact with personal data during their engagement with Varden Axis Ltd.
 

For the purposes of data protection legislation, Varden Axis Ltd acts as a data controller. This means we are responsible for deciding how and why we hold and use personal information. We are required to be transparent about how personal data is handled, and this document fulfils that legal requirement.

This notice contains detailed information and should be read carefully. If you have any questions, please contact us using the details provided at the end of this document.

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We may update this notice periodically. Where significant changes are made, individuals will be informed. However, it is important that this notice is reviewed regularly to remain up to date.

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2. DATA PROTECTION PRINCIPLES

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In accordance with data protection law, personal data must be:

  • Used lawfully, fairly, and transparently

  • Collected only for specified, explicit, and legitimate purposes

  • Adequate, relevant, and limited to what is necessary

  • Accurate and kept up to date

  • Retained only for as long as necessary

  • Processed securely and protected against unauthorised access or loss

Varden Axis Ltd is responsible for ensuring these principles are upheld.

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3. THE KIND OF INFORMATION WE HOLD ABOUT YOU

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Key points:

Personal data refers to information that identifies an individual. This does not include data where identification has been removed (anonymous data).

Some categories of personal data are classed as special category data or criminal offence data, which require a higher level of protection.

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Personal data we may collect includes:

  • Name, title, and contact details

  • Date of birth

  • Gender

  • Marital status and dependants

  • Emergency contact details

  • National Insurance number

  • Bank account and payment details

  • Tax and payroll information

  • Start and end dates of engagement

  • Engagement location or workplace

  • Right‑to‑work documentation (passport, visa, permits)

  • Recruitment materials (CVs, references, application details)

  • Employment or engagement records (roles, responsibilities, hours, training)

  • Performance‑related information

  • Disciplinary or grievance information

  • IT usage and system access records

  • Photographic identification where required

  • Results of HMRC employment status checks

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Special category data may include:

  • Health, medical, sickness, and absence information

  • Race or ethnicity

  • Religious or philosophical beliefs

  • Trade union membership

  • Sexual orientation

  • Biometric data (where applicable)

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Criminal offence data may include:

  • Information relating to criminal convictions or offences where legally permitted and relevant

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4. HOW IS PERSONAL INFORMATION COLLECTED?

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We collect personal data through:

  • Direct engagement with individuals

  • Recruitment processes

  • Employment agencies or service providers

  • Professional advisers and referees

  • Public professional platforms (such as LinkedIn)

  • HMRC and regulatory checks

Additional information may be collected throughout an individual’s engagement with Varden Axis Ltd.

All personal data is stored securely using appropriate technical and organisational safeguards.

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5. HOW WE USE PERSONAL INFORMATION

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We will only process personal data where permitted by law, including:

  • To perform a contract

  • To comply with legal obligations

  • For legitimate business interests

  • Where consent has been provided (where required)

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Purposes include:

  • Recruitment and engagement management

  • Payroll and payment processing

  • Tax, pension, and benefits administration

  • Compliance with HMRC and employment law

  • Managing working relationships

  • Performance, training, and development

  • Disciplinary and grievance processes

  • Maintaining system security and preventing fraud

  • Managing disputes, complaints, or insurance matters

If required information is not provided, we may be unable to meet contractual or legal obligations.

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6. USE OF SPECIAL CATEGORY DATA

Special category personal data will only be processed where necessary and lawful, including:

  • Compliance with employment law

  • Assessing fitness for work

  • Managing statutory payments and benefits

  • Making reasonable workplace adjustments

Consent will only be requested where legally required.

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7. INFORMATION ABOUT CRIMINAL CONVICTIONS

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We will only process information relating to criminal convictions or offences where permitted by law and where relevant to the role, engagement, or regulatory requirement.

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8. AUTOMATED DECISION‑MAKING

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Varden Axis Ltd does not currently make decisions based solely on automated processing. Should this change, individuals will be informed in advance.

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9. DATA SHARING

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Personal data may be shared with:

  • HM Revenue & Customs

  • Pension providers

  • Payroll, IT, and professional service providers

  • Legal, audit, and insurance advisers

  • Regulatory bodies

All third parties are required to protect personal data and process it only in accordance with our instructions.

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10. DATA SECURITY

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We have implemented appropriate technical and organisational measures to protect personal data, including access controls, encryption, and confidentiality obligations.

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11. DATA RETENTION

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Personal data is retained only for as long as necessary to meet legal, contractual, and regulatory obligations. Data is securely deleted or destroyed when no longer required.

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12. YOUR DATA PROTECTION RIGHTS

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Individuals have the right to:

  • Access personal data

  • Request correction of inaccurate data

  • Request erasure

  • Restrict processing

  • Object to processing

  • Request data portability

Requests should be submitted in writing using the contact details below.

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13. RIGHT TO WITHDRAW CONSENT

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Where processing is based on consent, consent may be withdrawn at any time by contacting us.

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14. DATA PROTECTION CONTACT

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For questions or concerns about this notice or how personal data is handled, please contact:

📧 admin@vardenaxis.co.uk

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

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15. CHANGES TO THIS PRIVACY NOTICE

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This notice is not contractual. Varden Axis Ltd reserves the right to update it at any time and will issue a revised version when significant changes are made.

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