Reach Engineering and Diving Services Limited (REDS) understands that your privacy is important to you and

that you care about how your personal data is used. We respect and value the privacy of all of our customers,

suppliers and staff and will only collect and use personal data in ways that are described here, and in a way,

that is consistent with our obligations and your rights under the law.

1. What does this notice cover?

This Data Privacy Information, together with any documents referred to in it, explains how we collect, store,

use and other wise process your data. It also explains your rights under the law relating to your personal data.

2. What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") as

'any information relating to an identifiable person who can be directly or indirectly identified in particular by

reference to an identifier'.

Personal data is, in simpler terms, any information about you that enables you to be identified.

Personal data covers obvious information such as your name and contact details, but it also covers less obvious

information such as identification numbers, electronic location data, and other online identifiers.

Non-personal data refers to any information that does not identify you as a specific individual. This policy may

include non-personal information where both types may be linked by the same document.

3. How we collect your data

We collect data in a number of ways, including in person, via email, via the website, by phone, post or social

media, such as:

  • Applying for a vacancy on our website, an external website or through social media
  • Offering your services for potential future vacancies
  • Using our website
  • Sending in your CV (curriculum vitae), certificates or other details, to update our records
  • Making an enquiry
  • By any other means that we may communicate with you

4. What personal data we collect

We may collect some or all of the following personal data (this may vary according to your relationship with


  • Personal information (such as name, address, phone number, contact details, date of birth, job title)
  • Tax information (such as NI number, UTR number)
  • Payment information (such as bank details, pay rates)
  • Next of kin details
  • Legal documents (such as passport, driving licence)
  • Skills evidence information (such as CV’s, training certificates, qualifications)
  • Health information (such as driving questions, medication or allergies)
  • Security information (such as site security pass details)
  • For those applying for employment or security passes; information including, but limited to,
    employment history, education history, relationship information, referee contact details
  • Criminal conviction information
  • Moving Images and recordings (such as CCTV footage)
  • Still images (such as photographs)
  • Any network information related to use of a device on REDS network
  • Health & Safety incident information
  • Any other details you choose to submit on a CV
  • Any other information required to perform our duties adequately

REDS shall collect your data from several pieces of data that you may provide us, for example, when applying

for a vacancy. However, REDS have no control over additional information that you choose to provide us within

documents such as your CV.

In some cases, we may collect data from third parties. This might include HMRC who provide tax verification

information, certain clients who might provide site security clearance details, or intermediaries who may act

as an introducer. If this happens we shall inform you of the source of the data, including if it came from a

publicly accessible source.

If you fail to provide REDS with data that is required for certain functions, it may mean that we are unable to

fulfil our requirement for entering into a contract with you or performing the contract that we have entered


REDS will only collect criminal conviction data where it is appropriate given the nature of the services you are

to provide to us and where the law permits us. This data will usually be collected during contract negotiation,

or in order to perform client requested security checks, however, may also be collected during your

engagement. We use criminal conviction data to determine your suitability, or your continued suitability for

the engagement. Certain clients may use this data to produce site security clearance or applicable caveats to

apply to your site security clearance. You will be informed in advance if a criminal data search is needed as

part of any such security checks. We rely on the lawful basis of legitimate interest to process this type of data.

5. How we use your personal data

Under the GDPR, we will only use your personal data when we have a legal basis for doing so. The legal basis

for using your personal data will depend on what we need to do but includes:

  • Contract: for us to provide services we have agreed to provide to you
  • Legal obligation: for us to comply with the law, this includes examples such as HMRC, and Health & Safety Executive

  • Vital Interests: for us to be able to protect someone’s life
  • Legitimate Interest: where necessary for our interests or the interest of a third party, but only after
    carefully considering any effect this may have on you, and in particular your rights and freedoms

  • Consent: where you have given us clear consent to use your data for a specific purpose. You have the right to withdraw your consent at any point

  • Public Interest: where processing is necessary for us to perform a task carried out in the public interest

We do not use any automated systems or profiling systems for carrying out any data processing.

6. How long we keep your personal data

REDS retain a record of your data in order to provide a high quality service to our customers and workforce.

We will only retain your data in accordance with the law and we will only retain it for as long as is necessary.

How long we will need to keep your personal data will depend on the purpose it was collected for and our

basis in law for keeping it.

Your data will be disposed of securely once it is no longer needed.

7. How and where we store your personal data

REDS shall protect your data against accidental loss or disclosure, destruction and abuse. Numerous measures

are taken to protect your data, depending upon the nature of the storage.

Where any personal data is to be erased or otherwise disposed of for any reason, it shall be securely deleted

and disposed of.

8. Who we share your personal data with

REDS will not sell, rent, trade or otherwise disclose your data, except as described in this policy, or other

documents referred to in this policy. The way that REDS operates means that we may need to share your

personal data between departments internally or with GDPR compliant external third parties so that we can

provide the service to you.


Employees within REDS who have a responsibility within project management, operations, health & safety,

recruitment, and payment will have access to your data which is relevant to their function. All employees with

such responsibility will be trained in ensuring the data is processed in line with GDPR.


Data may be shared with third parties for particular reasons, including but not limited to:

  • To verify details with HMRC for pay and deductions
  • To facilitate any payment arrangements
  • To obtain references or other relevant data
  • To complete security paperwork or checks in order for you to work on client sites
  • To inform contractors or clients of personnel names, contact details and applicable
    training/competence details, in order to verify your suitability for the work

  • To inform a site supervisor, or other relevant site personnel, of the personnel details related to that project

  • To inform a doctor of details relating to you for the purposes of providing medical attention
  • Contacting your emergency contact / next of kin in the event of an incident involving you
  • As part of an internal or external audit
  • To post, courier or deliver an item to you
  • If we are involved in legal proceedings or complying with legal obligations, a court order, or the

instructions of a government authority, where we may be legally required to share certain data (for

example the Police)

In all cases, shared data will be limited to that required to perform the task.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons

to comply with a legal obligation upon us. A data processing agreement would be in place with such third

parties to ensure data is not compromised. Third parties must implement appropriate technical and

organisational measures to ensure the security of your data.

Outside of EEA:

REDS may from time to time transfer personal data to countries outside of the EEA (European Economic Area,

being all EU member states, plus Norway, Iceland, and Liechtenstein), for the purposes of our legitimate

interests in performing a contract. Such countries may include The Channel Islands, Isle of Man, Gibraltar and

USA. REDS would ensure that any data transferred shall be done securely and that the bodies who receive the

data that we have transferred, process it in a way required by EU and UK data protection laws.

9. Your rights regarding your data

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. a) The right to be informed about our collection and use of your personal data. This Privacy Notice should
    tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.
  2. b) The right to access the personal data we hold about you.
  3. c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or
  4. d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal
    data that we have.
  5. e) The right to restrict (i.e. prevent) the processing of your personal data.
  6. f) The right to transfer the data we hold on you to another party. This means that you can ask us for a
    copy of your personal data held by us to re-use with another service or business in many cases.
  7. g) The right to object to us using your personal data for a particular purpose or purposes.
  8. h) The right to regulate any automated decision-making and profiling of your personal data. We do not
    use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please

contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner's Office

( ) or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a

complaint with the Information Commissioner's Office.

10. How you can access your personal data

If you wish to see the personal data we hold for you, you can ask us for details of that personal data. This is

known as a "data subject access request".

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part

  1. To make this as easy as possible for you, a Data Subject Access Request Form, is available for you to use.

We request the use of this form, as it is the easiest way to tell us everything we need to know to respond to

your request as quickly as possible. Before providing any information, we will need to verify your identify and

may request further information from you.

There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or

excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative

costs in responding.

We will aim to respond to your subject access request within two weeks but in any case, not more than one

month of receiving it. Normally, we aim to provide a complete response within that time, however, in some

cases, particularly if your request is more complex, more time may be required up to a maximum of three

months from the date we receive your request. You will be kept informed of our progress.

11. How to contact us

To contact us about anything to do with your personal data and data protection, including to making a data

subject access request, please use the following details

Email address:

Postal Address: REDS Ltd, Unit 2, Estate Road No. 6, South Humberside Ind. Est., Grimsby, DN31 2TG

Reach Engineering & Diving Services Ltd (REDS) is the data controller.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the

law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website.


This Policy has been approved and authorised by:

Name:Paul Gardener

Position: Director

Date: 01/02/2021