Privacy Policy

Privacy Notice

This policy covers the privacy policy for the SMB HR portal. You can view the policy for the SMB.co.uk marketing website here

Effective Date: 19 June 2026

INTRODUCTION

Welcome to the SMB Partners Limited (SMB) privacy notice.

SMB respects your privacy and is committed to protecting your personal data in accordance with the UK General Data Protection Regulation ("UK GDPR"), the UK Data Protection Act 2018, the Privacy and Electronic Communications Regulations ("PECR"), the Data (Use and Access) Act 2025 ("DUAA") and other applicable data protection laws.

Where SMB processes data that is subject to the EU General Data Protection Regulation (EU GDPR), references in this notice to UK data protection legislation should also be read as including the equivalent provisions of the EU GDPR where applicable.

This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. DATA PROTECTION COMPLAINTS
11. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice This privacy notice explains how SMB collects, uses, stores and protects personal data processed through the SMB HR portal and associated support services. It also explains the respective roles of SMB and its customers, your privacy rights and how applicable data protection laws protect you.

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.

Our status as a data processor

SMB acts as a data processor for its customers. If you are employed by a customer, then that customer is the data controller (which means that they determine the means and purposes of that processing) and we are the customer's processor. That means that we process Personal Data according to the instructions of our customers. Our customers are companies who engage us to manage their employee records.

This website is intended to be used by employees of our customers, who will either be using the site for human resources management or administration purposes, or who will be accessing their own employee record.

In relation to most employee and workforce information stored within the SMB HR portal, SMB acts solely as a processor on behalf of its customers. The relevant customer (typically your employer or former employer) is the controller and determines why and how your personal data is processed.

In certain limited circumstances SMB acts as a controller. For example, SMB processes personal data relating to customer contacts, support requests, platform security, service administration, billing, legal compliance and business operations for its own purposes.

As a processor of employee-related data we take seriously the private nature of the information that we process, and the importance of it being accurate. However, this website/portal contains the ability for our customers to input data into user-defined fields. All our customers are expected to use the website in compliance with their general legal obligations and our Terms and Conditions of Use, but we have limited control over what may be included within user-defined fields in particular. It is therefore important that you refer to the privacy policy of the relevant customer to understand how they will use this site.

Data Protection Officer

We have appointed a data protection officer (DPO) (The DPO Centre, www.dpocentre.com) 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 DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: SMB Partners Ltd
Email address: dpo@smb.co.uk
Postal address: 4th Floor 100 Avebury Boulevard, Milton Keynes, United Kingdom, MK9 1FH
Telephone: 0203 797 6340

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.

We would also recommend that you raise any complaint with your employer, who will usually be the relevant controller and may be best placed to assist.

Changes to the privacy notice

This notice may be updated from time to time to reflect changes in our services, legal obligations or regulatory guidance. The latest version will always be available through the SMB HR portal.

Third-party links

Our customers have the ability to add links to their own websites and intranets. This website/portal may therefore include links to third-party websites, plug-ins and applications where the individual user has the necessary permissions. 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.

2. 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).

The data we collect is provided by our customers for the purposes of their human resources management.

We use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes home address, email address and telephone numbers.
  • Financial Data includes bank account and similar details.
  • 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.
  • Usage Data includes information about how you use our website and services.
  • Customer Data this is data that our customers input into the website for the purposes of HR management. There are various fields relating to specific aspects of each individual employee, and their relationship with our customer. Depending on how the portal is configured, Customer Data may include:
    • employment history;
    • job title and organisational information;
    • absence and leave records;
    • performance and appraisal information;
    • training and qualification records;
    • disciplinary and grievance information;
    • emergency contact details;
    • benefits and compensation information;
    • diversity and equality monitoring information;
    • health and wellbeing information;
    • other workforce management information determined by the relevant customer.

We also collect, use and share Aggregated Data such as statistical or demographic data. 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 website/portal 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

Special Categories of Personal Data

The HR portal may process Special Category Data and, where applicable, criminal offence data where this has been determined by the relevant customer to be necessary for employment, social security, equality monitoring, safeguarding, health and safety, legal compliance or other legitimate workforce management purposes.

Examples may include information concerning:

  • racial or ethnic origin;
  • religious or philosophical beliefs;
  • trade union membership;
  • health information;
  • biometric data (where used by the customer);
  • criminal offence information (where lawfully processed).

SMB processes such information solely on behalf of and under the documented instructions of the relevant customer acting as controller.

3. HOW WE COLLECT YOUR PERSONAL DATA

The vast majority of data that we process originates from our customers, or from individual employees of those customers. This data is provided by users authorised by our customers to access their account and to populate the appropriate data fields with employee information, or by individual employees updating that information during the course of their employment.

Personal data may therefore be collected from:

  • your employer or former employer;
  • authorised HR, payroll or management personnel;
  • you directly when using the portal;
  • system-generated activity and audit logs;
  • technical interactions with the portal and supporting services.

Cookies

A small part of the data we collect is Usage Data, which results from users' interactions with our site. This informs us how long individual users spend on the site, and what they do whilst on it.

We also collect Technical Data by way of automated technologies or interactions. As you interact with our website/portal, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

The SMB HR portal primarily uses cookies and similar technologies that are necessary for authentication, security, session management and operation of the platform.

Where non-essential cookies or similar technologies are used, SMB will ensure that any required consent is obtained in accordance with applicable law.

We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Our clients might link their own website/portal account to notice boards, SharePoint sites or YouTube videos that could result in further cookies being dropped. We have no control over these additional links. Please refer to your organisation's own privacy and cookie information to understand any additional processing that may occur through those third-party resources.

Controller processing of Technical and Usage Data

SMB acts as controller in relation to certain Technical Data and Usage Data that it processes to operate, secure, maintain and improve the HR portal and associated support services.

The lawful basis for this processing is SMB's legitimate interests in maintaining a secure, reliable and effective platform and, where applicable, the performance of contractual obligations owed to customers.

We use Technical and Usage data to monitor our portal performance and to provide technical support as required.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as GoCardless based inside the EU or PayPal or Stripe based inside the EU. They are controllers in their own right as we do not process the personal data it is processed via direct API and we only receive confirmation of successful payment.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to.

Processing carried out by SMB as processor

Where SMB acts as a Processor, we process personal data solely on the documented instructions of our customers and only for purposes connected with the provision, operation, support and maintenance of the HR portal and related services.

Our terms and conditions can be found here.

These set out our contractual obligations to our customers, including the extent of the authority that we have to process data provided to us.

We process this data because of our contractual obligations to our customers.

We do not use personal data collected through the SMB HR portal for our own marketing purposes, nor do we make automated decisions about individuals using customer HR data except where instructed by the relevant customer and permitted by law.

Our customers remain the data controller, and are responsible for identifying and communicating the applicable lawful basis (and, where relevant, Article 9 condition) for their processing activities.

Special Category Data

Where Special Category Data or criminal offence data is processed through the SMB HR portal, such processing is carried out on behalf of and under the instructions of the relevant customer acting as controller. SMB processes such information only to the extent necessary to provide the services and in accordance with contractual and legal requirements.

Processing carried out by SMB as controller

In certain circumstances SMB processes personal data as controller.

The table below explains the principal categories of controller processing carried out by SMB.

Purpose/Activity Categories of Data Lawful Basis
Providing customer support and responding to enquiries Contact data, communications data, account information Legitimate interests
Managing customer relationships and contracts Contact data, account data, correspondence Performance of a contract and legitimate interest
Maintaining portal security, monitoring performance and preventing misuse Technical data, usage data, audit logs Legitimate interests
Managing billing, service administration and business operations Contact data, account information, transactional information Contract and legitimate interests
Handling complaints and regulatory matters Contact data, correspondence and relevant records Legal obligation and legitimate interest
Complying with legal, regulatory and professional obligations Relevant personal data necessary for compliance Legal obligation

Change of purpose

We will only use your personal data for the purposes for which we collected it.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share personal data with trusted third parties where reasonably necessary to operate, support, secure and improve the SMB HR portal and associated services. Such disclosures will only take place where there is an appropriate legal basis and, where required, suitable contractual safeguards.

The categories of third parties with whom personal data may be shared include:

  • hosting and cloud infrastructure providers;
  • customer support and service management providers;
  • email and communications service providers;
  • IT support and software providers;
  • professional advisers, including legal, audit and insurance advisers;
  • regulators, law enforcement agencies, courts or governmental authorities where required by law; and
  • other service providers engaged to support delivery of the SMB HR portal and related services.

Where SMB acts as a processor, any disclosures will generally take place only on the documented instructions of the relevant customer acting as controller, unless disclosure is otherwise required by law.

Key Service Providers and Sub-processors

SMB uses carefully selected service providers to support the delivery, security and operation of the SMB HR portal. These may include:

Provider Purpose}
Fasthosts (www.fasthosts.co.uk) Hosting and infrastructure services
Zendesk(www.zendesk.com) Customer support and ticket management
Mailchimp (www.mailchimp.com) may be used to facilitate the delivery of transactional and service-related communications associated with use of the platform.
Microsoft www.microsoft.com SMB uses Microsoft services, including Microsoft 365 and Microsoft Azure, to support business operations, communications, hosting and service delivery.

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 regard these as sub-processors, which means that we have in place contracts with each company that provide the same degree of commitment to data protection as exists between us and our customers, and in particular means that they may only process it for the purposes for which it is provided to them. They must return or delete it at our request.

Disclosures Required by Law

We may also disclose personal data where required to do so by law, regulation, court order, regulatory request or other legal process, or where disclosure is necessary to establish, exercise or defend legal claims.

Business Transfers

If SMB undergoes a merger, acquisition, corporate reorganisation, investment transaction or sale of assets, personal data may be disclosed to relevant advisers, prospective purchasers or successor organisations, subject to appropriate confidentiality and data protection safeguards.

6. INTERNATIONAL TRANSFERS

Some of our service providers, sub-processors and business partners may process personal data outside the United Kingdom or European Economic Area ("EEA"). This may include processing in jurisdictions that do not benefit from an adequacy decision from the UK Government or European Commission.

Where personal data is transferred internationally, SMB implements appropriate safeguards to protect that information and ensure compliance with applicable data protection laws. Depending on the circumstances, these safeguards may include:

  • UK adequacy regulations;
  • European Commission adequacy decisions;
  • the UK International Data Transfer Agreement ("IDTA");
  • the UK Addendum to the EU Standard Contractual Clauses ("SCCs");
  • Binding Corporate Rules ("BCRs");
  • approved codes of conduct or certification mechanisms; or
  • other legally recognised transfer mechanisms.

Examples of providers that may involve international processing include:

Purpose Location Provider Transfer Mechanism
Customer Support International (including USA) Zendesk SCCs, UK Addendum and/or other approved safeguards
Email Communications International (including USA) Mailchimp SCCs, UK Addendum and/or other approved safeguards
Cloud Services and Hosting International Microsoft SCCs, UK Addendum, adequacy decisions and/or other approved safeguards
Cloud Infrastructure and Support Services International Amazon Web Services SCCs, UK Addendum and/or other approved safeguards

Before transferring personal data internationally, SMB assesses the relevant transfer arrangements and, where required, implements supplementary measures designed to maintain an appropriate level of protection.

f you want further information on the specific mechanism used by us when transferring your personal data out of the EEA/UK, please contact us using the contact details provided in this notice.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, or altered or disclosed.

These measures include, where appropriate:

  • access controls and role-based permissions;
  • authentication and password controls;
  • encryption of data in transit and, where appropriate, at rest;
  • system monitoring and logging;
  • vulnerability management and security patching processes;
  • business continuity and disaster recovery measures; and
  • staff training and confidentiality obligations.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions and they are subject to appropriate confidentiality obligations.

We have put in place procedures to identify, investigate, manage and respond to suspected personal data breaches.

Where required by law, we will notify the relevant controller, affected individuals and/or applicable regulators of a personal data breach.

Where SMB acts as a processor, breach notifications will normally be made to the relevant customer acting as controller in accordance with applicable contractual and legal requirements.

8. DATA RETENTION

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.

Where SMB acts as a processor, retention periods are primarily determined by the relevant customer acting as controller. SMB will retain, return, archive or delete personal data in accordance with documented customer instructions, contractual obligations and applicable legal requirements.

Where SMB acts as a controller, personal data will be retained only for as long as necessary for the relevant business purpose and in accordance with SMB's retention policies and legal obligations.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you).

Where data has been irreversibly anonymised, we may use that information for research, statistical analytical or service improvement purposes without further notice to you.

Personal data will be securely deleted, returned or anonymised when it is no longer required, subject to any applicable legal or regulatory retention requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Your rights may vary depending on whether SMB is acting as controller or processor in relation to the relevant processing activity.

For most employee and workforce data processed within the SMB HR portal, SMB acts as processor and the relevant customer acts as controller. In such circumstances, requests should generally be directed to the relevant customer.

However, SMB will provide reasonable assistance to customers in responding to data subject requests where required by law or contract.

Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

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.

10. DATA PROTECTION COMPLAINTS

If you have concerns about how SMB has handled your personal data, you may submit a data protection complaint to us:

  • by email at dpo@smb.co.uk;
  • through our website contact or complaint form;
  • or in writing to our registered office.

Please provide enough information for us to understand and investigate the issue, including relevant dates, details of your concern and any supporting information.

We will acknowledge receipt of your complaint within 30 days as required by law, although we aim to respond sooner where possible. We may request additional information where reasonably necessary to verify your identity or clarify the complaint.

We will investigate complaints fairly and keep you updated where appropriate. Once our investigation is complete, we will explain the outcome and any action taken.

If you remain dissatisfied, you have the right to complain to the Information Commissioner's Office (“ICO”). Further information is available on the ICO website.

11. GLOSSARY

LAWFUL BASIS

Legitimate 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

THIRD PARTIES

External Third Parties

Service providers acting as processors or sub-processors who provide IT and system administration services.

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. You also have the right to object where we are processing your personal data for direct marketing purposes. 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.

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