PRIME Commitment Limited
Privacy Notice
PRIME Commitment Limited (“PRIME”) is committed to being transparent about its processing of personal data and to meeting its data protection obligations. This privacy notice is intended to provide you with information on PRIME’s obligations under Articles 13 and 14 of the UK General Data Protection Regulation (“UK GDPR”). PRIME is the data controller in respect of all personal data collected and processed in relation to your employment or volunteering with us.
This privacy notice applies to all personal data processed relating to employees, volunteers, prospective employees and prospective volunteers of PRIME located in the UK. When we talk about the “processing” of personal data we mean collecting, recording, storing, organising, amending, accessing, disclosing or disclosing / sending to someone else outside PRIME. Importantly this term also covers the destruction or the simple retention of information.
1. Personal data processing
PRIME will collect the following categories of personal data about you:
| Category |
Data collected |
What it is used for |
| Employees |
Name, address, email, telephone number, bank details |
HR and payroll purposes. |
| Volunteers |
Name, address, email, telephone number |
HR purposes. |
| Prospective employees |
Name, address, email, telephone number, career history, education history |
HR purposes. |
| Prospective volunteers |
Name, address, email, telephone number, career history, education history |
HR purposes. |
We may obtain your consent to disclose sensitive personal data (such as personal data that relates to race or ethnic origin and health) when we are required to do so by law. If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.
2. Sources of information
The personal data PRIME holds about you is data received directly from you (for example, through the application and recruitment process, by completing forms or by corresponding with us by mail, phone, email or otherwise) but PRIME may also:
- receive data about you from other sources (for example, from referees that you provide as part of the application and recruitment process); and
- create data about you in the course of any activities throughout the period of you working or volunteering for us.
3. Information Processing and Sharing
Purpose and legal basis for processing
PRIME will process personal data about you for the following legal bases:
| Personal data |
Purpose of processing |
Legal bases for processing |
| In relation to employees: name, address, email, telephone number, bank details. |
HR and payroll purposes. |
· Performance of any contract with you;
· Compliance with a legal obligation to which we are subject;
· Where you have freely provided consent for a particular purpose; and
· Our legitimate interests, which may include:
o the running and management of our charitable purpose to provide fair access to the legal profession, such as through the planning and organisation of work, personnel management, accounting and auditing; and
o assessing suitability of employees / volunteers for potential roles and keeping records of employee / volunteer activities and performance.
|
| In relation to volunteers: name, address, email, telephone number. |
HR purposes. |
· Performance of any contract with you;
· Compliance with a legal obligation to which we are subject;
· Where you have freely provided consent for a particular purpose; and
· Our legitimate interests, which may include:
o the running and management of our charitable purpose to provide fair access to the legal profession, such as through the planning and organisation of work, personnel management, accounting and auditing; and
o assessing suitability of employees / volunteers for potential roles and keeping records of employee / volunteer activities and performance. |
| In relation to prospective employees and volunteers: name, address, email, telephone number, career history, education history. |
HR purposes. |
· Compliance with a legal obligation to which we are subject;
· Where you have freely provided consent for a particular purpose; and
· Our legitimate interests, which may include:
o the running and management of our charitable purpose to provide fair access to the legal profession, such as through the planning and organisation of work, personnel management, accounting and auditing; and
o assessing suitability of employees / volunteers for potential roles and keeping records of employee / volunteer activities and performance.
|
When we process personal data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information about the balancing test that we carry out to process your personal data to meet our legitimate interests, please contact us at the details below.
With whom we will share your personal data
We may share your personal data with third parties under the following circumstances:
- Colleagues. We may share your data with colleagues within PRIME where it is necessary for them to undertake their duties. For example, the person supervising you may need your information in order to effectively, and safely, facilitate your role.
- Referees. We may share your data with third parties in order to obtain references as part of the recruitment process, and, if appropriate, complete DBS checks or other pre-recruitment screenings.
- Law enforcement agencies, courts, regulators and government authorities. We may share your personal data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
- Asset purchasers. We may share your personal data with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal data uses it in a manner that is consistent with this privacy notice.
Sharing your personal data internationally
PRIME will not transfer your data outside of the UK.
4. Your rights
- You have certain rights regarding your personal data, subject to local law. These include the right to:
- access your personal data;
- rectify the information we hold about you;
- erase your personal data;
- restrict our use of your personal data;
- object to our use of your personal data;
- receive your personal data in a usable electronic format and transmit it to a third party (right to data portability); and
- lodge a complaint with your local data protection authority.
If you would like to discuss or exercise such rights, please contact us at the details below.
We encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate.
- We will contact you if we need additional information from you in order to honour your requests.
5. Security and retention of your personal data
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.
We will keep your personal data for no longer than is necessary for the purposes for which the personal data is processed and to the extent permitted by applicable laws.
6. Contact Us
PRIME is the controller responsible for the personal data we collect and process. If you have questions or concerns regarding the way in which your personal data has been used, please contact our Engagement Consultant at admin@primecommitment.co.uk.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office.
7. Changes to the Policy
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. If we change this privacy notice, we will notify you of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
Updated September 2025.
