Trust Box Nanny Agency Privacy Policy

INTRODUCTION 

We are a recruitment agency and recruitment business as defined in under the Companies Act 1963 (Act 179). We collect information about you to carry out our core business and ancillary activities. This privacy notice provides you with details of how Trust Box Nanny Agency (“we”, “our”, “us”) collect and Process your Personal Data, whether you’re a client, nanny agent, a supplier or another third party.

“Personal Data” is any information identifying a living, identifiable individual, excluding any anonymous data but including any sensitive

Personal Data. Such data can be factual such as a name, email address, date of birth or national insurance number; or an opinion or reference about a person’s actions or behavior.

“Processing” or “Process” means any activity involving the use of Personal Data whether that is obtaining, holding, recording or carrying out any operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying it.

It includes the transmission or transferring Personal Data to third parties. Trust Box Nanny Agency are the data controllers and we are responsible for your Personal Data, including determining when, why and how to Process Personal Data. Our email address is tbna.ghana@gmail.com. Our postal address is P.O. Box 36 ML Mallam, Accra-Ghana.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Data Protection Commission (DPC), the Ghana supervisory authority for data protection issues (www.dataprotection.org.gh). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. It is very important that the information we hold about you is accurate and up to date.

Please let us know if at any time your personal information changes by emailing us at tbna.ghana@gmail.com

BACKGROUND 

This policy has been written in accordance with the principles and safeguards set out in the Data Protection Commission (DPC) (2012/843). We adhere to the principles relating to the Processing of Personal Data set out in DPC which require Personal Data to be:

• Accountability
• Lawfulness Of Processing
• Specification Of Purpose
• Compatibility Of Further Processing With Purpose Of Collection
• Quality Of Information
• Openness
• Data Security Safeguards
• Data Subject Participation

HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when legally permitted. The most common uses of your Personal Data are:

• Where we need to perform the contract between us either

i) In accordance with our terms and conditions of business if you are a client;

ii) In accordance with our terms of representation if you are a nanny agent or

iii) In accordance with the relevant terms of supply between us as businesses.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal ground for

Processing your Personal Data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at tbna.ghana@gmail.com

Purposes for Processing your Personal Data

Set out below is a description of the ways we intend to use your Personal Data and the legal grounds on which we will Process such data. We have also explained what our legitimate interests are where relevant.

We may Process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at tbna.ghana@gmail.com if you need details about the specific legal ground we are relying on to Process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity Type of Data Lawful basis of Processing.

To register you as a new client the following are needed:

• Identity
• Contact
• Details concerning your family

To find a suitable nanny agent for your family in accordance with our legal terms and conditions

To register you as a new nanny agent the following are needed:

• Identity
• Contact
• Job experience
• Skills and qualifications

To comply with your legal terms and conditions and use all reasonable endeavors to find you suitable employment/engagement

To process your invoice

• Manage payments

Collect and recover money owed to Trust Box Nanny Agency

• Identity
• Contact
• Financial
• Transaction
• Marketing and communications
• Performance of a contract with you.
• Necessary for our legitimate interests to recover debts owed to us.

To manage our relationship with you as a supplier

• Identity
• Contact
• Financial
• Transaction
• Marketing and communications
• Performance of a contract with you
• Necessary for our legitimate interest to manage and run our business.

To manage our relationship with you, including notifying you about changes to our terms or privacy policy

• Identity
• Contact
• Profile
• Marketing and communications
• Performance of a contract with you
• Necessary to comply with our legal obligation
• Necessary for our legitimate interests to keep our records updated and to study how clients use our services.

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

• Identity
• Contact
• Technical
• Necessary for our legitimate interest for running our business, provision of administration and IT services, network security and to prevent fraud
• Necessary to comply with a legal obligation

To use data analytics to improve our website, services, marketing, client relationships and experiences

• Technical
• Usage

Necessary for our legitimate interests to define types of clients for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy.

To make suggestions and recommendations to you about services that may be of interest to you

• Identity
• Contact
• Technical
• Usage
• Profile

Necessary for our legitimate interests to develop our services and grow our business.

Information we obtain from other sources.

In addition, we may obtain information about our nanny agents from other sources such as job board websites, online CV libraries, references, personal recommendations, and referees. Such information shall be held by us for the purpose of complying with our obligations to our clients and nanny agents. For further details on the sources from which we obtain Personal Data on nanny agents and the purposes for which we use it, please refer to our privacy policy.

Marketing communications 

You will receive marketing communications from us if you have:

(i) Requested information from us or registered with us as a nanny agents or clients; or

(ii) If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and

(iii) In each case, you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing tbna.ghana@gmail.com at any time. Where you opt out of receiving our marketing communications, this will not apply to Personal Data provided to us as a result of us providing you with a service or other transaction.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your Personal Data with the parties set out below for the purposes set out in the table in paragraph 2 above:

• Clients who are looking for suitable nanny agents to fulfil a role that they are offering.
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

DISCLOSURES OF YOUR PERSONAL DATA 

We may have to share your Personal Data with the parties set out below for the purposes set out in the table in paragraph 2 above:

• Clients who are looking for suitable nanny agents to fulfil a role that they are offering.
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Ghana Revenue Authority (GRA), regulators and other authorities based in the Republic Of Ghana and other relevant jurisdictions who require reporting of Processing activities in certain circumstances.

Third parties to whom we sell, transfer, or merge parts of our business or our assets:

We require all third parties to whom we transfer your data to respect the security of your Personal Data and to treat it in accordance with the law. We only allow such third parties to Process your Personal Data for specified purposes and in accordance with our instructions.

DATA SECURITY 

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only Process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION 

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal

Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we Process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep basic information about our clients (including Contact, Identity,

Financial and Transaction Data) for as long as you continue to use our services. In some circumstances you can ask us to delete your data and it is our responsibility to make sure that any Personal Data we retain is accurate. So, if you would like us to erase your data (to the extent that we are able) or there are any changes to your data which means what we currently hold is inaccurate, please do let us know. 

YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These include the right to:

• Request access to your Personal Data.
• Request correction of your Personal Data.
• Request erasure of your Personal Data.
• Object to Processing of your Personal Data.
• Request restriction of processing your Personal Data.
• Request transfer of your Personal Data.
• Right to withdraw consent.

You can see more about these rights at: https://www.dataprotection.org.gh/data-protection/data-protection-principles

If you wish to exercise any of the rights set out above, please email us at tbna.ghana@gmail.com

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).

This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month.

Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.