UHI United Hospitality Institute Ltd and its affiliates (referred to as “we”, “our”, or “UHI”) recognise and respect the rights and privacy of individuals. This includes our applicants, current and former employees, suppliers, trainers, trainees and customers.
This Notice explains what we do with your personal data, whether we are considering your application for employment, continuing our relationship with you, providing you with a service, receiving a service from you, or if you are visiting our premises or our website.
It describes how we collect, handle, and process your personal data, and how, in doing so, we comply with our legal obligations. We consider privacy to be important and we are committed to protecting and safeguarding your data privacy rights. The use of the word “processing” in this Notice is intended to include such actions as collecting, handling, using, storing and protecting your personal data.
This Notice applies to the personal data of Data Subjects such as yourself, our Employees (on board and ashore), Customers, Visitors, Suppliers of goods and services, Website Users, and others whom we may contact in order to collect more information about our employees or those whom they have indicated as an Emergency contact.
If you are a member of staff, you should also refer to the company Data Protection Policy and Data Protection Handbook, with which we have already provided you.
This Notice is written to comply with the applicable data protection legislation which includes, but is not limited to, the European Union General Data Protection Regulation (GDPR).
The company responsible for your personal Data (Data Controller)
Phone: +357 25843320
Address: Dodekanison, Columbia House, 4043 Limassol, Cyprus
Data Protection Officer
Name: Mr Andreas Andreou
Phone: +357 2584100
Address: Columbia House, 21 Spyrou Kyprianou Avenue, 4042 Limassol, Cyprus
How do we use data?
We may process personal data as part of our services. Such processing may include, but is not limited to, employment contracts, anti-money-laundering, risk management, claims handling, document processing, marketing and training.
What personal data do we collect?
In order to consider you for employment, or employ you, we need to process certain information about you. We only ask for or collect details that help us provide what is required as part of your application process or employment. For example, we need information such as your name, age, contact details, education details, employment history, emergency contacts, next of kin, immigration status, passport size photos, passport copies, overalls size, bank account details, utility bills and other relevant information required for the purposes of your employment or that you may choose to share with us. Where appropriate, and in accordance with local laws and requirements, we may also collect information of a more sensitive nature, such as diversity information, information related to your health, or details of any criminal convictions.
To enable us to communicate with you and to ensure that we meet certain legal requirements such as KYC (know your customer) and AML (anti-money-laundering), we need to have certain details of yours or details of individual contacts at your organisation (such as their names, telephone numbers and e-mail addresses).
We ensure that our marketing communications to you are relevant and timely.
We collect a limited amount of data in order to improve your experience when using our website.
This includes information such as the frequency with which you access our website, and the times that our website is most popular.
Suppliers of goods and services
We collect a small amount of information from our Suppliers to ensure that operations work properly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
As part of due diligence and in order to protect the vital interests of our Data Subjects, we will under certain circumstances collect emergency contact details.
When visiting our premises, we collect the necessary personal data required for security and notification purposes. For security purposes, we also operate a Closed Circuit Television system (CCTV). The CCTV cameras only operate in common areas of our premises and are positioned so as not to intrude on privacy. The footage is kept for no longer than a month and access is strictly regulated.
The legal bases we use for lawful processing
In order to conduct business and fulfil our legal, regulatory, and contractual obligations, we need to perform legitimate and fundamental processing activities. These are:
- Establishing contracts
- Maintaining contracts
- Provision of all contracted services
- Invoicing: remittance, payments, and collections
- Non-promotional communications
- Marketing and other promotional communications
- Risk management contract review
- Response to subject requests
- Performance measurement
- IT and telecommunication support services
- Business continuity and contingency planning
- Legal and regulatory obligations
- Responding to enquiries, requests, and complaints
- Employment processing
- Workforce planning
- Training and certifications
- Emergency communications
- Interacting with other organisations, industry groups, and professional associations
- Internal ethics reporting, security, and investigations
Who will access or receive the data?
We need to share the personal information we process with individuals themselves and also with other organisations. The list below contains a description of the types of organisations with which we may need to share some of the personal information we process.
- Agents and brokers
- Business associates, other professional bodies, and advisers
- Central and local government
- Claimants, beneficiaries, assignees, and payees
- Claims investigators
- Complainants, and enquirers
- Courts and tribunals
- Credit reference, debt collection, and tracing agencies
- Current, past, and prospective employers
- Debt collection and tracing agencies
- Education and examining bodies
- Employment and recruitment agencies
- Family, associates, and representatives of the person whose personal data we are processing
- Financial organisations and advisers
- Healthcare professionals, social and welfare organisations
- Law enforcement and prosecuting authorities
- Ombudsman and other regulatory authorities
- Other affiliated companies
- Pension schemes
- Police forces
- Private investigators
- Professional advisers
- Share Administrators
- Suppliers and services providers
- Survey and research organisations
- Unions, trade associations, professional bodies, and employer associations
The countries where data will be stored, processed and/or transferred
Your personal data we collect may be stored and processed in the EU or any other country in which we or associated third parties maintain facilities. In case we need to transfer your personal data, we will take all reasonable measures to safeguard the transfer of your personal data to third parties in a manner that complies with the applicable data protection laws.
How long will the data be retained?
Retention of specific records may be necessary for one or more of the following reasons:
- Fulfilling statutory or other regulatory requirements
- Evidencing events/agreements in case of disputes
- Operational needs
- Historical and statistical purposes
Where we collect personal data for which we subsequently have no use for any business purpose we will then review and may destroy such personal data at our discretion.
The right to withdraw consent
In situations where we request and receive your consent to perform processing, we are also obliged to stop such processing if you decide to withdraw your consent. Withdrawing consent is as straightforward as giving consent. Withdrawing consent cannot be back-dated so it has no effect on processing already performed during the period of consent.
The right to access, change, delete, restrict, object, request a copy
Under certain circumstances you have rights regarding your personal data. These are:
- Access to a copy of your personal data
- Object to processing that you object to
- Stop receiving direct marketing material
- Object to decisions being taken by automated means
- Have inaccurate personal data rectified, blocked, erased or destroyed
- Lodge a complaint with the relevant data protection authority
- Claim compensation for damages caused by a breach of the GDPR
If you are an employee, and wish to exercise any of these rights, please follow the relevant company procedure. If you are not an employee, please contact UHI directly.
What happens if the data is not collected?
Your personal data is required for communication and setting up a contractual agreement to provide employment, products, and services. Without this data we will not be able to communicate with you or enter into a contractual agreement with you. This includes both business and employment contracts.
We need personal data to:
- Enable consensual bilateral communications
- Engage in pre-contractual activities
- Honour contractual obligations
- Be able to employ people
Without this data, we will not be able to perform these primary activities.
Automated decision making
We do not use automated decision making.
A cookie is a small file placed onto internet enabled devices in order to recognise a device upon recurring visits, and in turn enable a website’s features and functionalities. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Cookies may transmit information via a device’s browser with a purpose of authentication or identification via the IP address. For example, cookies enable us to identify a device, secure access to our websites, and keep track of web browsing preferences.
Cookies may also be used for recognising you as the user when you visit our website, remembering your preferences, and overall giving you a more personalised experience that’s in line with your settings.
Essentially there are two types of cookies:
- persistent cookies, and
- session cookies
A persistent cookie helps the website (and third party applications) to recognise you as an existing user, so it is easier to return and continue your existing user experience.
Session cookies are temporary cookies that remain on your device until you leave the website.
Our websites only utilise persistent cookies when any browser loads the site, essentially for keeping track and observing website visitor trends and statistics. This is applicable to various internet enabled devices, e.g. PC’s, smartphones and tablets.
Cookies may also be placed in your browser when visiting our website via third party application plugins or when using third party modules on the website. This applies when using social media “sharing” tools via third party application plugins. We do not, however, have access to details regarding your social media or personal data during this process. We can only see which pages of our website have been shared collectively over social media and how many times.
The table below demonstrates the cookies that we use and explains why we use them.
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|_gid||Used to distinguish users.|
|_gat||Used to throttle request rate.|
|__utmt||Used to throttle request rate.|
|__utmc||Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.|
Controlling Cookies on your Device
Cookies on an internet device help make the user experience of our websites better.