DATA PRIVACY STATEMENT
1.1 Shepper Limited and its group companies (“we”, “our” or “us”) provide this Data Privacy
Statement to inform our contractors of our policy relating to the processing of their personal
1.2 This statement sets out the basis on which we will process your personal information. Please
read it carefully to understand our practices regarding your personal information and how
we will use it.
1.3 This statement does not form part of any contract of employment or contract to work or
provide services and may be amended at any time.
2. ABOUT US
2.1 We are the data controller of the personal data of contractors, and are subject to applicable
data protection laws.
If you have any questions about this data privacy statement or your Information, or wish to
exercise any of your rights as described in this statement or under applicable data protection
laws, you can contact our Operations team:
By email: firstname.lastname@example.org
By phone: 0345 3194535
3. WHAT TYPES OF DATA ARE PROTECTED
3.1 Personal data
This Data Privacy Statement applies to your “personal data”, which is any information
relating to you as an identified or identifiable person. This data is referred to in this Data
Privacy Statement as “Information”).
3.2 Special categories of personal data
Within the broad range of personal data, the following are “special categories of personal
data” which are subject to a greater degree of protection:
• physical or mental health;
• racial or ethnic origin;
• political opinions;
• trade union membership;
• religious beliefs;
• sexual life; and
• genetic and biometric data.
4. WHAT INFORMATION WE COLLECT
4.1 Information you give us
4.1.1 You may give us Information by filling in forms online or by corresponding with
us by phone, email, in person, or otherwise. This includes Information you
provided when you first applied to work with us.
4.1.2 To assist us in complying with our obligation to maintain accurate Information,
you should immediately notify the Operations team in writing of any changes to
your personal details. Such changes may include, but are not limited to:
• your name, change of address, phone number or mobile phone number;
• your nationality or immigration status;
• any change of address, phone number etc.;
• your bank details.
Failure to comply with this requirement may constitute a disciplinary offence.
4.1.3 Where you have notified us or we otherwise become aware of an inaccuracy in
Information, we will take steps to ensure that Information is erased or rectified
4.2 Information we collect about you
4.2.1 We collect Information to operate our business and manage your work (where
applicable), to meet service level agreements (SLA’s) and to comply with our
legal and regulatory obligations as a contracting party.
4.2.2 We may collect, store and use Information relating to your use of our IT systems.
4.2.3 The Information that we may collect about you includes, but is not limited to,
• home address;
• contact details (such as phone numbers and email addresses);
• copies of your passport, driving licence and similar documents;
• languages spoken and level of proficiency;
• IP addresses.
4.3 Using your information to target online advertising at other prospective Shepherds
When we advertise on the internet for the recruitment of Shepherds, we may share your
information with our advertising partners, so that they can target our ads at their other
users who have a similar profile to you. For example, when we use social media for
marketing purposes, your name and other identifier such as email address may be shared
with the social media platform, so that they can check if you also hold an account with
them. If you do, we may ask the advertising partner or social media network:
• to exclude you from receiving our adverts (as you are already a Shepherd!)
• To advertise to people who have a similar profile to you, e.g. if we believe that the
idea of becoming a Shepherd will appeal to people with similar interest to the ones
on your social media profile, we may ask our advertising partner to send our adverts
to people who share your interests.
You can contact us to object to us sharing your personal data in this way for online
advertising. Social media platforms also allow you to indicate your preferences to them
about the advertising you receive on their platforms. Please contact your social media
platforms for more information.
4.4 Special categories of personal data
Information includes such “special categories of personal data” (see the description
5. INFORMATION PROVIDED BY THIRD PARTIES
5.1 We may also collect Information from external sources, such as those that are commercially
available to us.
5.2 Some of the Information we collect (as described in section 4), and additional Information,
may be provided to us by recruitment agencies with whom you have registered an interest.
Such recruitment agencies support our recruitment processes under a duty of
5.3 We may also receive Information from organisations such as credit reference agencies, fraud
prevention agencies and referees.
6. DATA RELATING TO CRIMINAL CONVICTIONS & OFFENCES
6.1 We may also collect and store personal data relating to criminal convictions and offences.
This data is only processed:
• if you have given your consent to the processing; or
• if it is necessary for the purposes of performing or exercising our or your obligations
or rights under law; or
• if it is necessary for the prevention or detection of an unlawful act and it is
necessary for reasons of substantial public interest; or
• in connection with any legal proceedings (including prospective legal proceedings)
and/or the obtaining of legal advice.
7. WHAT WE DO WITH YOUR INFORMATION AND ON WHAT BASIS
7.1 We process Information (other than special categories of personal data) for the reasons
listed below. The legal justification for the processing of the Information is, in each case,
one or more of these reasons. Specific examples are given – some of which may overlap, as
there may be more than one reason for processing Information.
7.2 Processing is necessary for the performance of your contract
We have obligations towards you under the terms of your contract (for example, we are
contractually obliged to pay you any money due under your contract). Equally, you have
contractual obligations to us, both as part of entering into your contract and in the ongoing
performance of it. In order for us to ensure that both we and our contractors can perform
our contractual obligations, we may process Information for the following purposes (where
• onboarding processes (e.g. communicating with you in relation to your application);
• considering your suitability for work, taking up your references and conducting
• induction processes;
• complying with our legal and regulatory obligations;
• training and training records;
• payment processes and administration of your contract;
• monitoring SLA’s;
• Shepper’s Strike Policy;
• criminal records checks;
• undertaking business analysis activities.
7.3 Where we have a legal or regulatory obligation
UK and EU law and certain rules and regulations require us to process Information in order
to comply with our legal or regulatory obligations. In order for us to do so, we may process
Information for the following purposes (where applicable):
• preventing illegal working;
• complying with health and safety obligations;
• ensuring the safety and security of our systems;
• carrying out equal opportunities monitoring;
• responding to government statistical monitoring (Office for National Statistics);
• assessing Fitness and Propriety of individuals for regulatory purposes;
• providing regulatory references; and
• communicating with the PRA, FCA or other public or regulatory bodies.
7.4 Where we have a legitimate interest
7.4.1 Data protection law allows us to process Information where it is necessary for
the purposes of our legitimate interests. We consider it to be in our legitimate
interests to process Information for the following purposes:
• onboarding processes (including negotiation and communicating with you
in relation to your application);
• considering your suitability for work, taking up references, and conducting
• administering our IT system including troubleshooting, data analysis,
testing, research, statistical and survey purposes;
• dealing with any legal disputes involving you or other current, prospective
or former contractors;
• improving our IT system to ensure that content is presented in the most
effective manner for you and for your computer, mobile device or other
item of hardware through which you access our IT system;
• ensuring the safety and security of those working for us;
• as part of our efforts to keep our IT system safe and secure and to monitor
compliance with our related policies;
• reporting to government entities.
7.5 If you do not agree with the processing of Information on the basis that it is in our legitimate
interests to do so, please inform us using the contact details at the beginning of this Data
Privacy Statement, following which we shall cease to process Information for that purpose,
unless certain exceptions apply: see “Right to object to processing in certain circumstances”
under “Your rights” below.
7.6 Special categories of personal data
7.6.1 We may process “special categories of personal data” for the purposes of:
• performing or exercising our or your obligations or rights under law,
including for assessing suitability for particular jobs and considering
whether adjustments may need to be made to accommodate an individual
with a disability;
• where it is in the public interest, such as for equal opportunities
• establishing, bringing or defending legal claims.
7.6.2 We may also process “special categories of personal data” in other limited
circumstances, with your explicit written consent. We do not need your consent
to process “special categories of personal data” in circumstances where we
already have a legal right to do so and we carry out such processing in accordance
with this statement. If we do ask you for your written consent, we will provide
you with full details of the information we are seeking from you and the reason
why, in order for you to make an informed decision. It is not a condition of your
contract that you agree to any such request by us.
8. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
8.1 For the purposes set out in section 7 above, we may share Information with:
• our group companies;
• professional advisors (including lawyers, accountants and auditors);
• legal and regulatory authorities such as the PRA and FCA; and
• HM Revenue & Customs and other government/state related entities.
8.2 We may also share Information with other parties which provide products or services to us,
such as our software providers, in order to enable us to comply with our overriding legal
and regulatory obligations to you and to ensure that we comply with your contract. These
third parties will also be data controllers of Information, which will be processed in
8.3 We may also disclose Information to third parties where it is in our legitimate interest to do
so, including for the following reasons:
• in the event that we sell or buy any business or assets, in which case we may disclose
Information to the prospective seller or buyer of such business or assets; or
• if we are under a duty to disclose or share Information in order to comply with any
8.4 Save as set out in this Data Privacy Statement, or as required by law, we do not sell
Information or disclose it to any third parties without your consent.
9. POLICIES AND PROCEDURES
9.1 We have a number of additional policies, which are updated from time to time, in relation
to data privacy and data security. Please familiarise yourselves with these additional
policies. If you have any questions about such policies and procedures, you should speak to
the Operations team.
9.2 Any new or updated policies or manual will be communicated to you by email, or any other
10. SECURITY OF YOUR INFORMATION
10.1 We are committed to ensuring that your Information is safe and we will take all steps
reasonably necessary to ensure that your Information is treated securely and in accordance
with this Data Privacy Statement.
10.2 All Information you provide to us electronically is stored on our secure servers within the
United Kingdom and the U.S.A.
10.3 Where we have given you (or where you have chosen) a password which enables you to
access certain parts of our IT system, you are responsible for keeping this password
confidential. We ask you not to share your passwords with anyone.
10.4 Unfortunately, the transmission of information via the internet is not completely secure.
Although we will do our best to protect your Information, we cannot guarantee the security
of your Information transmitted to or stored on our IT system, and any transmission is at
your own risk. Once we have received your Information, we will use strict procedures and
security features to try to prevent unauthorised access.
11. HOW LONG WE KEEP YOUR INFORMATION
We will keep your Information for as long as necessary to fulfil the purposes described in
this Data Privacy Statement or in the terms of your contract, or for as long as we are
required to do so by law or in order to comply with a regulatory obligation.
12. YOUR RIGHTS
12.1 Access to your Information and updating your Information
• You have the right to access Information that we hold about you, subject to certain
limited exceptions provided by law. If you so request, we shall provide you with a
copy of Information which we are processing and hold about you (“data subject
access request”). Further details about data subject access requests can be found
in our Data Protection Policy. For any further copies which you request, we may
charge a reasonable fee based on administrative costs.
• You also have the right to receive such Information in a structured and commonly
used format so that it can be transferred to another data controller (“data
• We want to make sure that your Information is accurate and up to date. You may
ask us to correct or remove information which you think is inaccurate.
12.2 Right to object to processing in certain circumstances
You also have the right to object, on grounds relating to your particular situation, at any
time to the processing of your Information which is based on our legitimate interests. Where
you object on this ground, we shall no longer process your Information unless:
• the processing is nevertheless necessary for the performance of your contract or
contract to work or provide services; or
• the processing is necessary for the establishment, exercise or defence of legal
• we have a legal or regulatory obligation for which the processing of the Information
is necessary; or
• we can demonstrate that our legitimate interest is sufficiently compelling to override
your fundamental rights and freedoms.
12.3 Your other rights
12.3.1 You also have the right to request that we rectify your Information if it is
inaccurate or incomplete.
12.3.2 In certain limited circumstances, you have the right to request the erasure of
your Information (‘right to be forgotten’).
13. EXERCISING YOUR RIGHTS
13.1 You can exercise any of your rights as described in this Data Privacy Statement and under
data protection laws by contacting us via the details given in the “Contacting us” box above.
13.2 Save as described in this Data Privacy Statement or provided under data protection laws,
there is no charge for the exercise of your legal rights. However, if your requests are
manifestly unfounded or excessive, in particular because of their repetitive character, we
may either: (a) charge a reasonable fee, taking into account the administrative costs of
providing the information or taking the action requested; or (b) refuse to act on the request.
13.3 Where we have reasonable doubts concerning the identity of the person making the request,
we may request additional information necessary to confirm your identity.
14. INTERNATIONAL TRANSFERS
14.1 As an international organisation, authorised personnel may access your Information in any
country in which we operate. Therefore, it may be necessary to transfer your details to
members of our group located in countries that may not offer equivalent data protection or
privacy laws to those in the UK or the EU.
14.2 Regardless of where your Information is transferred, we shall ensure that your Information
is safe and shall take all steps reasonably necessary to put in place appropriate safeguards
to ensure that your Information is treated securely and in accordance with this statement
and applicable law. Details regarding these safeguards can be obtained from the Operations
team, whose details are given above.
You also have the right to complain to the Information Commissioner’s Office
(https://ico.org.uk/) about our data processing activities. The Office has a dedicated
helpline at 0303 123 1113.
16.1 This Data Privacy Statement may be amended by us at any time in our sole and absolute
discretion. Any changes which may be made to this Statement in the future will be notified
to you by email and on our intranet.
16.2 This Data Privacy Statement was last updated on 25th March 2019.