Welcome to Paycircle’s Privacy Notice.
Paycircle respects your privacy and is committed to protecting your personal data.
This privacy notice will inform you as to how we look after your personal data when you visit our Website or use our Application, whether you are using it as an employer or an employee or user (regardless of where you visit our Websites from or use our Application) and tell you about your privacy rights and how the law protects you.
Important information and who we are
Paycircle is responsible for this website. As a summary, Paycircle is a payroll application used by employers to process personal data of their employees in order to facilitate their legal payroll and pension obligations.
Purpose of this Privacy Notice
This privacy notice aims to give you information on how Paycircle collects and processes your personal data through your use of this website, including any data you may provide to us when you use our application to receive services as an employer, or upload your information as an employee, or sign up to receive our newsletter.
This website nor our application is intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data Protection Legislation
Paycircle and you are required to comply with all applicable requirements of the Data Protection Legislation. The Data Protection Legislation means, as applicable: (a) the UK retained General Data Protection Regulation (EU 2016/679 GDPR) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK; (b) the Data Protection Act 2018; and (c) the Privacy and Electronic Communications (EC Directive) Regulations 2000 and any applicable replacement or supplementary legislation in the UK.
Controller and Processor
If you are utilising our services as an employer:
Paycircle shall be the data controller of the information that you provide to Paycircle in order for Paycircle to set you up as a customer (set out below).
If you are utilising our services as an employee:
Paycircle shall be collectively referred to as “Paycircle”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
- Company name:
- Paycircle Limited, registration number 11356087
- Name or title of DPO:
- David Hart
- Email address:
- Postal address:
- 85 Great Portland Street, London W1W 7LT
- Telephone number:
- 0203 640 7788
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 10 September 2021 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth, profile images and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, security questions and answers, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and our application, product and services.
Additional data we collect about you if you are an employee:
- Identity Data: national insurance number, company identifier, profile images, gender.
- Financial / Employment Data: tax codes, salary, payroll details and IDs, worksheets, expenses, job details, historic payroll figures, pension scheme details, Attachment of Earnings orders, employment start and leave dates.
- Medical Data includes sickness and maternity records. Your employers will have the relevant consent and authorisations in place in order to allow this information to be processed to us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) (other than outlined above). Nor do we collect any information about criminal convictions and offences (other than outlined above).
If you fail to provide personal data
Where we need to collect personal data by law, or process data under the terms of a contract we have with you as an employer, and you as an employer fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In such cases, we may have to cancel the services that we are providing to you as an employer, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- the use of our application;
- creating an account;
- subscribe to our services or publications or newsletters;
- give us some feedback.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you, your employer or your employer’s data processor.
- 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.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that 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 contact us 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 for processing including basis of legitimate interest|
|To facilitate the employer’s legal payroll and pension obligations||(a) Identity|
(c) Financial and Employee Data
|Necessary as part of our performance of a contract with your employer or your employer’s data processor.|
|To process your payments to you as an employee||(a) Financial and Employee Data||Necessary as part of our performance of a contract with your employer or your employer’s data processor.|
|To register you as a new customer/user||(a) Identity|
|Performance of a contract with you as the employer or with your data processor.|
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity|
|(a) Performance of a contract with you as the employer or with your data processor. (b) Necessary for our legitimate interests (to recover debts due to us)|
|(a) Performance of a contract with you as the employer or with your data processor. (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)|
|To administer and protect our business and this website and our application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website and application content to you and measure or understand the effectiveness of the service we serve to you||(a) Identity|
|Necessary for our legitimate interests (to study how customers use our products)|
|To use data analytics to improve our website and application, products and services||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our app updated and relevant)|
- Information about the type of device you use;
- Your IP address; and
- Hyperlinks you have clicked on our website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Paycircle Group, however we will not be transferring any of your data outside of the EEA. If this position changes we shall notify you of the same.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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. 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.
How long will you use my personal data for?
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 unauthorised 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 have to keep information about our users (including Contact, Identity, Financial and Transaction Data) for seven years for tax purposes.
|Data Category||Retention Policy||References|
|Personal Details (Names, gender, DOB, NI Number, address etc.)||Six historic years plus current year. To give employee and employer reference and to provide identity and context to the below. ||As below.|
|Pay / Payroll Data (Historical pay information and payroll identifiers)||Six historic years plus current year. As prescribed by law – see references.|
- Taxes Management Act 1970
- Income Tax (PAYE) Regulation 2003
|Pension Data (Pension scheme data, historical contributions, correspondence)||Six historic years plus current year. As prescribed by law – see references.|
- The Pensions Acts 1995, 2004, and 2008
- The Occupational Pension Schemes (Scheme Administration) Regulations 1996
- The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013
- The Occupational Pension Schemes (Internal Controls) Regulations 2005
- The Data Protection Act 1998
- The IORP Directive
In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information. If your personal data is required to be held as required as part of your employer’s ongoing legal obligations then you as the employee, cannot restrict this processing or request the right to be forgotten until the relevant data retention period has expired.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
- 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.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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 a number of requests. In this case, we will notify you and keep you updated.
Lawful basisLegitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External third parties
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services including Pensionsync (Systemsync Solutions Limited) - a middleware we use to make submissions to pension providers.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances including to comply with legal payroll and reporting obligations.
- Pension providers including Nest, Now, Smart, Aviva, Peoples Pension, Legal & General as applicable.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.