GuildGateway App Privacy Notice

This privacy notice covers use of the GuildGateway app. If you are registered with Guild Commercial Limited or Guild Freelancing Limited, you should refer to their respective privacy notices to understand how those companies make use of your data to fulfil their legal and contractual obligations and manage consent and their legitimate interests.

This privacy notice covers how your personal information may be used within and by the GuildGateway app (only).

‘We’ are Guild Corporate Services Group Limited (company number 05106109), The Construction Workers Guild Limited (company number 03357288), The Guild of Construction Workers Limited (company number 04192823), CWG Services Limited, Guild Freelancing Limited (company number 10439306), Guild Assist Limited (company number 11681335), GuildHub Consulting Limited (company number 13385870), whose registered address is Fifth Floor, 79 College Road, Harrow, HA1 1BD, and for these purposes, Guild Commercial Limited (company number 70827), whose registered office is at Ground Floor, Dorey Court, Admiral Park, St Peter Port, Guernsey, GY1 2HT.

We act as both a data controller and a data processor for data protection purposes. We are committed to complying with the GDPR (2016), the UK GDPR (2021), the Data Protection Act (2018) and any data protection law that may apply from time to time.

Personal data is information that can be used to identify a human being, whether by itself or in combination with other data.

Your privacy rights are important to us. This privacy notice will detail the kinds of data we may process and how we use that data.

Categories of Data

You can use this app to access any data that you have provided as part of a Guild Commercial Limited or Guild Freelancing Limited registration:

Name, date of birth and contact details (including residential addresses)
ID and documents that may be used to evidence rights to live and work in the UK, where applicable (including nationality)
Technical information such as national insurance details, unique tax references or CIS registration details
Bank account information
Emergency contact details (generally, a name and contact number)

Some data is not personal data in isolation but is treated as such in combination with personal data. You may find some of this information in the app:

Skills, qualifications and experience
Languages
Trades or professions
Company or partnership information where applicable

Additionally, we may process some data related to download and use of the GuildGateway app:

Information about your device
IP address
Cookies preferences
Geographical location
Usage of the app
Collective data, such as (general) geographical, trade or profession or demographic information

The GuildGateway app does not process special category or criminal data (criminal convictions) pursuant to articles 9 or 10 of the GDPR. We do not knowingly we process data of, from or relating to children under 13.

Special Category Data

Special category data is personal data that is considered to be particularly sensitive. Special category data comprises data relating to: race or ethnicity; political opinions; religious or philosophical beliefs; information about trade union membership; genetic data; biometric data (where used for identification purposes); medical or health data; data about sex or sexuality.

Again, the GuildGateway app does not process this kind of data, and we do not collect it.

When Data is Collected

Data may be collected when:
You provide it by registering with Guild Commercial Limited or Guild Freelancing Limited (with administrative support from CWG Services Limited)
You visit The Guild’s website
You contact CWG Services Limited, Guild Commercial Limited or Guild Freelancing
You download and register for the GuildGateway app
You log in and use the GuildGateway app
You engage with social media platforms

Uses of Personal Data in The Guild Gateway App

Providing user access to ongoing and historic payments information and their personal data
Push notifications to provide information or payment updates from Guild Commercial Limited or Guild Freelancing Limited as may be applicable
Push notifications to provide information deemed as ‘marketing’ type communications where the user has provided consent for marketing communications to Guild Commercial Limited or Guild Freelancing Limited
Technical troubleshooting and improvements to The Guild Gateway app
Penetration testing and technical changes and improvements to the security of the GuildGateway app
Export of limited data to test environments in order to test fixes and improvements to the GuildGateway app
Understanding user experience of the app
Developing new functionality of the app. Please note that this privacy notice will be updated as new functions are added.
Supply chain auditing, data analysis and other processes to assess supply chain legal compliance

If you are registered with Guild Commercial Limited or Guild Freelancing Limited, you should refer to the relevant privacy notices you have been issued with for more detailed information about how those companies use your personal data to provide their services and meet their legal and contractual obligations.

We make use of 3^rd party software developers to maintain and update the GuildGateway app. Any 3^rd party software developers’ access to the app will be limited and subject to our oversight, and these developers will be under their own data protection obligations. Where a 3^rd party partner is based outside of the UK, any interactions will be treated as though they were operating in the UK for data protection purposes.

Please note that we may occasionally provide some personal information to our partners and clients where it is necessary to do so or a legitimate interest in doing so has been identified, such as for the purpose of supply chain audits. In these circumstances, we will aim to provide only information that is necessary for the purpose.

We may also provide some personal information to third parties such as government agencies, including law enforcement, where they have the legal authority to demand it.

Finally, we may also make use of data in or from the GuildGateway app for the purposes of preparing legal defences in the event or prospect of legal action.

Push Notifications for Marketing

Where you have provided consent for us to do so, we may send marketing communications via push notifications from the GuildGateway app.

As with any marketing communications, you have the right to withdraw consent for these push notifications at any time, via the app or by contacting CWG Services Limited, Guild Commercial Limited or Guild Freelancing Limited.

Future Functionality (3^rd Party Access)

Please be aware that the GuildGateway app may add new functions in the future, which may include 3^rd party service providers. This privacy notice will be updated as and when such functionality involves the use of 3^rd parties, such access will only be provided where an appropriate lawful basis has been identified and only to the extent that it does not disproportionately impact your data rights.

Subject Access Requests

You should be able to access your personal data via the GuildGateway app. However, you are entitled to make a subject access request. If you wish to make a subject access request, we suggest that you make it directly to Guild Commercial Limited, CWG Services Limited or Guild Freelancing Limited as may be applicable, however, where you make a subject access request to us, we will respond within one month, giving you a copy of your data, why we have it, who it could be disclosed to, the categories of data it involves, and it will be in a format that you can access easily. You have the right to clarify and correct the information. Personal data can be deleted providing that we do not think it’s required for legal or public interest reasons.

If your request is more complex, for example it involves other data subjects and we need their consent to release the relevant information, we can extend our response time to three months, but we will inform you of this. If they do not give their consent, we will anonymise this data or remove the relevant detail before sending this to you. We will not charge for data subject access requests unless they are excessive or manifestly unfounded. Then we will charge for administrative time only.

We try to make sure that any information in the GuildGateway app is accurate. If your details change, for example if you move home, you can use the GuildGateway app to request an update of your information. Alternatively, you can email Guild Commercial Limited, CWG Services Limited or Guild Freelancing Limited as may be applicable. Once they have been sent this request, a member of the team will contact you to verify the request and update your information.

This is to make sure your information is properly safeguarded. Information updates will be reflected in the GuildGateway app.

Data Retention

We will only retain your personal data in the GuildGateway app 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 and to assist you with your own such obligations. The law requires us to keep records, which includes personal information, for different periods of time.

If you delete the GuildGateway app, your personal data may be removed from the app. Please be aware that if you choose to delete the GuildGateway app, your personal data relating to your registration with Guild Commercial Limited or Guild Freelancing Limited will be stored on secure databases to meet their legal, accounting or reporting requirements, or where there is a legitimate interest, until such time as the data can be (legally) purged. This will relate to different legal limitation periods. If you are registered with Guild Commercial Limited or Guild Freelancing, you should refer to their respective privacy notices for further information about the uses and sharing requirements of personal data to get a clearer understanding of why data must be retained.

Data Security

No online or other means of communication can be 100% secure. Nevertheless, the GuildGateway app makes use of technical and security measures to safeguard any data within it.

Your Data Rights

Rights	What Does This Mean?
1. The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Notice.
2. The right of access	You have the right to obtain access to your information. This is so you are aware and can check that we are using your information in accordance with data protection law.
3. The right to rectification	You are entitled to have your information corrected if its inaccurate or incomplete.
4. The right to erasure	This is also known as the right to be forgotten and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right, there are exceptions.
5. The right to restrict processing	You have rights to block or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability	You have rights to obtain and reuse your personal data for your own purposes across different services. This is not a normal scenario for companies of our nature but if you have any questions you can contact us.
7. The right to object to processing	You have the right to object to certain types of automated processing or decision making, including processing for direct marketing or where we are relying on our legitimate interests for processing.
8. The right to withdraw consent	If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

Data Breaches

We have procedures in place to deal with any suspected personal data breach and will notify you and any supervisory body of a breach if we are legally required to in the event of a data breach.

Complaints

If you have a complaint, you can make it in writing, by email, via the GuildGateway app, the contact form in the online portal (if you have registered for it) or over the phone during office hours. These complaints should ideally be directed to CWG Services Limited in the first instance.

If you are unsatisfied, you are entitled to raise a data protection complaint to the Information Commissioner’s Office.

This privacy notice will be updated from time to time. You will be able to access the latest version of the privacy notice via the GuildGateway app.

This privacy notice was last updated on 29 July 2024.