Data Protection Policy
We may have to collect and use information about people with whom we work. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.
We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.
To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).
This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.
This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
C) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
- processing will be fair, lawful and transparent
- data be collected for specific, explicit, and legitimate purposes
- data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
- data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- data is not kept for longer than is necessary for its given purpose
- data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
- we will comply with the relevant GDPR procedures for international transferring of personal data
D) TYPES OF DATA HELD
We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system.
Specifically, we hold the following types of data:
- personal details such as name, address, phone numbers
- information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc.
- details relating to pay administration such as National Insurance numbers, bank account details and tax codes
- medical or health information
- information relating to your employment with us, including:
- job title and job descriptions
- your salary
- your wider terms and conditions of employment
- details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
- internal and external training modules undertaken
All of the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.
E) EMPLOYEE RIGHTS
You have the following rights in relation to the personal data we hold on you:
- right to be informed about the data we hold on you and what we do with it;
- the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
- the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
- the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
- the right to restrict the processing of the data;
- the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
- the right to object to the inclusion of any information;
- the right to regulate any automated decision-making and profiling of personal data.
More information can be found on each of these rights in our separate policy on employee rights under GDPR.
In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.
We have also appointed employees with responsibility for reviewing and auditing our data protection systems.
G) LAWFUL BASES OF PROCESSING
We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data.
However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.
H) ACCESS TO DATA
As stated above, employees have a right to access the personal data that we hold on them. To exercise this right, employees should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.
No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.
Further information on making a subject access request is contained in our Subject Access Request policy.
I) DATA DISCLOSURES
The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:
- any employee benefits operated by third parties;
- disabled individuals - whether any reasonable adjustments are required to assist them at work;
- individuals’ health data - to comply with health and safety or occupational health obligations towards the employee;
- for Statutory Sick Pay purposes;
- HR management and administration - to consider how an individual’s health affects his or her ability to do their job;
- the smooth operation of any employee insurance policies or pension plans;
- to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.
These kinds of disclosures will only be made when strictly necessary for the purpose.
J) DATA SECURITY
All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.
Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.
Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.
Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:
- ensuring that data is recorded on such devices only where absolutely necessary.
- using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
- ensuring that laptops or USB drives are not left where they can be stolen.
b) using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
c) ensuring that laptops or USB drives are not left where they can be stolen.
Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
K) THIRD PARTY PROCESSING
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.
L) INTERNATIONAL DATA TRANSFERS
The Company may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place because of trade and subsidiary relationships. Where this occurs, the following safeguards are adopted:
- In compliance with GDPR code of practice based on Article 29 Working
M) REQUIREMENT TO NOTIFY BREACHES
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
More information on breach notification is available in our Breach Notification policy.
New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.
P) DATA PROTECTION COMPLIANCE
Our Data Protection Officer can be contacted at:
+44 (0) 208 8388 355
Eagle Trans Group accepts its responsibilities for premises & sites operating during the Coronavirus Covid-19 pandemic need to ensure they are protecting their workforce and minimising the risk of spread of infection.
This policy is intended to introduce consistent measures in premises and sites of all sizes in line with the Government’s recommendations on social distancing.
These are exceptional circumstances and we will comply with the latest respective Government advice on Coronavirus at all times.
The Management have at the first instance carefully looked at the business and enabled all those who can and who should work from home to do so. Where this has not been possible, the business has undertaken a risk assessment to make the working environment as safe as it possible can to follow the Government’s guidance on Corona Virus. A risk assessment has been undertaken prior to any business activities resuming, a copy of this has been shared with all staff and is also available on our website in due course.
The health and safety requirements of any business activity must also not be compromised at this time. If an activity cannot be undertaken safely due to a lack of suitably qualified personnel being available or social distancing being implemented, it should not take place.
We are aware that emergency services are also under great pressure and may not be in a position to respond as quickly as usual.
Managers should remind the workforce at every opportunity of the Operating Procedures which are aimed at protecting them, their colleagues, their families and the population.
If a premises is not consistently implementing the measures set out below, it may be required to shut down.
This policy will be reviewed frequently and revised as necessary in response to changes in legislation or guidance on methods of working. Employees, contractors, suppliers, and consultants are all required to cooperate with us in making this policy work.
A) SELF ISOLATION
Anyone who meets one of the following criteria should not come to Office:
- processing will be fair, lawful and transparent
- Has a high temperature or a new persistent cough - follow the guidance on self-isolation
- Is a vulnerable person (by virtue of their age, underlying health condition, clinical condition or are pregnant)
- Is living with someone in self-isolation
B) PROCEDURE IF SOMEONE FALLS ILL
If a worker develops a high temperature or a persistent cough while at work, they should:
- Return home immediately
- Avoid touching anything
- Cough or sneeze into a tissue and put it in a bin, or if they do not have tissues, cough and sneeze into the crook of their elbow.
They must then follow the guidance on self-isolation and not return to work until their period of self-isolation has been completed.
C) TRAVEL TO WORK
Wherever possible workers should travel to site alone using their own transport and sites need to consider:
- Parking arrangements for additional cars and bicycles
- Other means of transport to avoid public transport e.g. cycling
- Providing hand cleaning facilities at entrances and exits. This should be soap and water wherever possible or hand sanitiser if water is not available
- How someone taken ill would get home.
D) BUILDING ACCESS POINTS
- Stop all non-essential visitors
- Monitor access points to enable social distancing – We may need to change the number of access points, either increase to reduce congestion or decrease to enable monitoring
- Remove or disable entry systems that require skin contact e.g. fingerprint scanners
- Require all workers to wash or clean their hands before entering or leaving the site
- Allow plenty of space (two metres) between people waiting to enter Office
- Regularly clean common contact surfaces in reception, office, access control and delivery areas e.g. scanners, turnstiles, screens, telephone handsets, desks, particularly during peak flow times
E) HAND WASHING
- Provide additional hand washing facilities to the usual welfare facilities
- Ensure soap and fresh water is readily available and kept topped up at all times
- Provide hand sanitiser where hand washing facilities are unavailable
- Regularly clean the hand washing facilities and check soap and sanitiser levels
- Provide suitable and sufficient rubbish bins for hand towels with regular removal and disposal.
Premises will need extra supplies of soap, hand sanitiser and paper towels and these should be securely stored.
F) TOILET FACILITIES
- Restrict the number of people using toilet facilities at any one time e.g. Signage
- Wash hands before and after using the facilities
- Enhance the cleaning regimes for toilet facilities particularly door handles, locks and the toilet flush
- Provide suitable and sufficient rubbish bins for hand towels with regular removal and disposal.
G) CANTEENS AND EATING ARRANGEMENTS
Whilst there is a requirement to provide a means of heating food and making hot drinks, these are exceptional circumstances and where it is not possible to introduce a means of keeping equipment clean between use, kettles, microwaves etc. must be removed from use if possible.
The workforce should also be required to stay on site once they have entered it and not use local shops as much as possible.
Dedicated eating areas should be identified on site to reduce food waste and contamination
- Break times should be staggered to reduce congestion and contact at all times
- Hand cleaning facilities or hand sanitiser should be available at the entrance of any room where people eat and should be used by employees when entering and leaving the area
- The workforce should be asked to bring pre-prepared meals and refillable drinking bottles from home
- Employees should sit 2 metres apart from each other whilst eating and avoid all contact
- Where catering is provided on site, it should provide pre-prepared and wrapped food only
- Payments should be taken by contactless card wherever possible
- Crockery, eating utensils, cups etc. should not be used
- Drinking water should be provided with enhanced cleaning measures of the tap mechanism introduced
- Tables should be cleaned between each use
- All rubbish should be put straight in the bin and not left for someone else to clear up
- All areas used for eating must be thoroughly cleaned at the end of each break, including chairs, door handles, vending machines and payment devices.
H) AVOIDING CLOSE WORKING
There will be situations where it is not possible or safe for workers to distance themselves from each other by 2 metres.
I) GENERAL PRINCIPLES
- Non-essential physical work that requires close contact between workers should not be carried out
- Work requiring skin to skin contact should not be carried out
- Plan all other work to minimise contact between workers
- Re-usable PPE should be thoroughly cleaned after use and not shared between workers
- Barriers & screens would be in place as applicable to protect those who cannot work 2M apart
- Workstations & Desks rearranged to be 2M apart or positioned in way in which persons are not facing each other
- Single use PPE should be disposed of so that it cannot be reused
- Stairs should be used in preference to lifts or hoists
- Where lifts or hoists must be used:
- Lower their capacity to reduce congestion and contact at all times
- Regularly clean touchpoints, doors, buttons etc.
- Increase ventilation in enclosed spaces
- Regularly clean the inside of vehicle cabs and between use by different operators.
- Virtual meetings if possible in the first instance
- Only absolutely necessary meeting participants should attend
- Attendees should be two metres apart from each other
- Rooms should be well ventilated / windows opened to allow fresh air circulation
- Consider holding meetings in open areas where possible.
- Enhanced cleaning procedures should be in place across the site, particularly in communal areas and at touch points including:
- Taps and washing facilities
- Toilet flush and seats
- Door handles and push plates
- Hand rails on staircases and corridors
- Lift and hoist controls
- Machinery and equipment controls
- Food preparation and eating surfaces
- Telephone equipment
- Key boards, photocopiers and other office equipment
Disclaimers for Eagle Trans Group
- All the information on this website - https://eagletrans-group.com - is published in good faith and for general and trade related information purpose only.
- Eagle Trans Group does not make any warranties about the completeness, reliability and accuracy of this information which could change from time to time and the latest information might have not been updated on the website.
- Any action you take upon the information you find on this website, is strictly at your own risk.
- Eagle Trans Group will not be liable for any losses and / or damages in connection with the use of our website unless a more specific business relationship is established by way of contacting one of the authorised personnel of Eagle Trans Group.
- Internet communications are not secure and therefore Eagle Trans Group does not accept any legal responsibility if and when communications are triggered via our website.
- Opinion or information contained within the website that is not part of the operations of Eagle Trans Group is not endorsed by Eagle Trans Group. Eagle Trans Group website does not provide any 3rd party links to other websites.
- The Photos used within the website have the copy right ownership of Eagle Trans Group or are under Creative Commons CC0 license.
- The names of legal entities mentioned within the website have been used purely for trade related promotions and with prior consent from the respective owners.
The country of Jurisdiction for the website is England.
By using our website, you hereby consent to our disclaimer and agree to its terms.
Should we update, amend or make any changes to this document, those changes will be prominently included for the viewer.
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If you require any more information or have any questions about our site's disclaimer, please feel free to contact us by email at firstname.lastname@example.org
Modern Slavery Statement
This statement applies to Inbrit Logistics Limited & Security Escorts Transsport ( 2004 ) Limited and Eagle Trans group). The information included in the statement refers to the financial year 2020 / 2021.
This statement also applies to all companies within and associated to Eagle Trans Group (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 2020/2021.
B) ORGANISATIONAL STRUCTURE
Inbrit Logistics Limited and Security Escorts Transport ( 2004 ) Limited are two companies based in London under Eagle Trans Group having their registered and trading Offices at Unit 3, Sovereign Park, Coronation Road, Park Royal. London NW10 7QP.
The organisations are controlled by a Board of Directors. The Trust owns a freehold Office building at the above address onbehalf of Inbrit Logistics Limited and Security Escorts Transport ( 2004 ) Limited, fully equipped with Office Contents to render office based freight forwarding and transport services. The companies have employed full time office staff and drivers to carry out activities pertaining to the freight forwarding sector which is mainly the preparation and control of shipping documents in order to facilitate a smooth export / import operation for the shippers and importers based in UK and Inland Transportation.
Our Freight Forwarding and Transport activities are consistent throughout the year and not seasonal based. The labour acquired by Inbrit Logistics Limited & Security Escorts Transport ( 2004 ) Limited are in pursuance of the operation carried out at the registered trading premises. The work is wholly carried out in the United Kingdom.
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group consider that modern slavery encompasses:
- Human trafficking;
- Forced work, through mental or physical threat;
- Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
- Being dehumanised, treated as a commodity or being bought or sold as property;
- Being physically constrained or to have restriction placed on freedom of movement.
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group acknowledge the responsibilities in relation to tackling modern slavery and commit to complying with the provisions in the Modern Slavery Act 2015. Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group understand that this requires an ongoing review of both the internal practices in relation to labour force and additionally, the supply chains.
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group do not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group strictly adhere to the minimum standards required in relation to its responsibilities under relevant employment legislation in the respective countries the employees are situated.
E) SUPPLY CHAINS
In order to fulfil the activities, Inbrit Logistics Limited being a Freight Forwarder and Security Escorts Transport ( 2004 ) being the Transport only liaise with the main stream UK based supply chains as applicable and gather information only in order to render services to the satisfaction of the clients.
F) POTENTIAL EXPOSURE
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited & Eagle Trans Group consider the exposure to slavery / human trafficking to be relatively limited. Nonetheless, we have taken steps to ensure that such practices do not take place in the business nor the business of any organisation that supplies services to them.
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group carry out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in the organisations or supply chains, including conducting a review of the controls of the suppliers.
The Organisations have not, to the knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group have taken the following steps to ensure that modern slavery is not taking place:
- reviewing your supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
- measures in place to identify and assess the potential risks in its supply chains;
- undertaking impact assessments of its services upon potential instances of slavery;
- creating action plans to address risk to modern slavery;
- any actions taken to embed a zero tolerance policy towards modern slavery;
H) KEY PERFORMANCE INDICATORS
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group have set the following key performance indicators to measure the effectiveness in ensuring modern slavery is not taking place in the organisations or its supply chains.
- Conducting one to one annual appraisals and periodic reviews with the staff force and analyse feedback
- Periodic site visits to the Load Points
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group have the following policy which further define its stance on modern slavery :
- To comply with contries Jurisdictions
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group provide the following training staff to effectively implement the stance on modern slavery :
- Induction programmes
- Refresher courses
- In house training
K) SLAVERY COMPLIANCE OFFICER
Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group have a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, who will then undertake relevant action with regard to Inbrit Logistics Limited, Security Escorts Transport ( 2004 ) Limited and Eagle Trans Group in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
Date of approval : 29th March 2021
Approved By : Compliance Officer
Date : 20th March 2021