Brookson Group and
Brookson One
Brookson Limited Privacy Notice
We are Brookson Limited (operating as Brookson One) of Brunel House, 320 Firecrest Court, Centre Park, Warrington, WA1 1RG a “data controller”.
This notice applies to prospective, current and former customers of the entity referenced above. This notice does not form part of any contract for the provision of services. We may update this notice at any time.
As a Data Controller, this means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
It is important that you read this notice, together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The Kind of Information We Hold 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).
“Special category” is data of more sensitive personal data about you and if we are provided with any such data, we will ensure it receives a higher level of protection.
We will collect, store, and use the following categories of personal information about you in order to identify you and facilitate the provision of our services to you. In order to do this, we will need to process the following personal data:
- Name
- Home address
- Residential address
- Work location
- Date of birth
- Title
- IP address/location
- Connect login and password details
- Bank details
- Unique tax reference number
- Nationality
- National Insurance Number
- Tax codes
- Email address and secondary email address
- Home, mobile and work/business telephone numbers
- Delegation authority name
- Eye colour
- Mother’s maiden name
- Birth town
- Historic addresses
- Personal income/tax returns and employment details
- Financial details
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your health, including any medical condition, health and sickness records from any Sick Note, Fit Note or other note or records provided by your doctor or medical professional from time to time, in order to assist you with any accounting services or relating to state benefits which you may be claiming or entitled to claim.
- Information about criminal convictions and offences which you may inform us about from time to time which may be used to provide advice your duties as a director, or your eligibility to act as a director of a business.
How is Your Personal Information Collected?
We collect personal information about customers through the initial engagement and on-boarding process, either directly from you over the telephone, or through submitting information to us via the brooksonone.co.uk website, or sometimes from an employment business/agency. We may also collect additional information from third parties including credit reference agencies or other background check agencies to confirm your identity and suitability for our services, or from your use of our website. We may also receive information from current customers (or customers of other members of the Brookson Group) who are looking to introduce their friends, colleagues and peers to our services as part of our ‘Recommend a Friend’ scheme from time to time.
We will also collect additional personal information in the course our engagement relating to the services which we provide.
We will collect this data from the following sources:
· E-mail
· Instant messaging
· Letters
· Online data capture forms
· Telephone calls (these may be recorded)
· Information from received directly from end clients
· Information received from recruitment businesses
All data received and recorded will only be used in accordance with the purposes set out below and where we have a legal basis for processing this data.
IP addresses and cookies
As is the case with most websites, we may obtain information about your usage of our web services through the use of cookies on our website. A cookie is a small piece of data placed on your hard drive in order to assist us in ensuring that your experience of using our website is optimised for your personal circumstances. Cookies cannot pass on computer viruses, retrieve other data from your computer’s hard drive or capture your email address. Cookies can be used to save users time on the site, by securely storing a user’s ID and password, personalise web pages and identify visited parts of a site and keep track of user’s selections. We use cookies to estimate our audience size and usage pattern, to speed up your searches and to collect information about your browsing habits and tailor our content, support and advertising in a manner relevant to our users. The data may then be used to track the user’s sites, via third-party vendors such as Google and may show adverts from us or other parts of the Brookson Group on those internet sites.
You have the option to opt-out and manage the cookies by altering the “help” settings on their browser. However, if you choose to disables the cookie, this can impair the functionality of our website and web services being used.
How We Will Use Information About You
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party). Where we are processing for a legitimate interest we have balanced this against your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where it is needed in the public interest or for official purposes.
We will use information about you for the following purposes:
- Advising and assisting you to making decisions about salary, remuneration and compensation (based on the terms of our engagement with you)
- Providing accounting, support services to you and your business (in accordance with the terms of our engagement with you)
- Providing bookkeeping support services to you and your business (in accordance with the terms of our engagement with you)
- Providing back office support services to you and your business (in accordance with the terms of our engagement with you)
- To provide you support and advice in relation to the completion, and filing, of self-assessment tax returns (in accordance with the terms of our engagement with you)
- Making decisions about your continued engagement with us (in accordance with the terms of our engagement with you)
- Making arrangements for the termination of our working relationship (in accordance with the terms of our engagement with you)
- Education and training on relevant information applicable to you/your business/working practices (in accordance with the terms of our engagement with you and/or our legitimate interests)
- Dealing with disputes involving you (in accordance with us performing our terms of our engagement with you)
- Ascertaining your fitness to act as a director of your business in compliance with legislation (in accordance with the terms of our engagement with you)
- Analysing assignment information which you are engaged on our behalf (including location of work, duration of working time, income, timesheet and invoicing information) to enable us to perform the terms of our engagement with you
- Understanding and analysing working patterns to ensure compliance with legal obligations (in accordance with the terms of our engagement with you)
- To prevent fraud (in accordance with our legal obligations)
- Processing payroll and making payments to your bank account(s) (in accordance with the terms of our engagement with you)
- To provide you with assistance in relation to accessing a pension scheme (in accordance with our legitimate interests)
- Analysing and processing eligibility for, and making payment of, expenses incurred during the course of your work (in accordance with the terms of our engagement with you)
- Informing recruitment businesses of necessary information in order to comply with obligations imposed by s44 Income Tax Earnings and Protection Act 2003 (in accordance with the terms of our engagement with you)
- To monitor your use of our information and communication systems to enable us to ensure that our software performs in accordance with our contract with you and to assess improvements and developments. This is to provide a better service and is in our legitimate interest to do so
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution to enable us to ensure that our software performs in accordance with our contract with you and to assess improvements and developments. This is to provide a better service and is in our legitimate interest to do so
- To conduct data analytics studies to review and better understand our customer base, remuneration, retention and attrition rates to enable us to ensure that our software performs in accordance with our contract with you and to assess improvements and developments. This is to provide a better service and is in our legitimate interest to do so
- To provide you with information and guidance on anything which may impact on atypical working in the recruitment/temporary worker sector (such as legislative changes, government consultations, sourcing statistical information to support our contribution to this sector of society) to enable in accordance with us performing our contract with you
- To provide you with information and guidance on efficient ways of working to maximise your take home pay and various vehicles used to provide services (such as personal service companies, sole trader/self employed, CIS and/or other models/vehicles available in the market). It is within our legitimate interest to do so
- To enable other businesses within the Brookson Group to notify you of support services which may be of interest to you or your business, it is within our legitimate interest to do so
- To notify you of offers, promotions, which may interest you or your business should you wish to refer a friend to us for employment within the Brookson Group or to use any of our products or services. It is within our legitimate interest to do so
- To provide you with updates, guidance, general and tailored advice which is (or may be in the future) relevant to you or your business in accordance with us performing our terms of engagement with you
- To assist you in opening a business bank account in accordance with your interests of being paid for work carried out and our legitimate interests of referring you to a banking partner which works seamlessly with our online platforms to support services to you and who may pay referral fees in accordance with our terms of engagement with you
- To enable third party insurance providers (Kingsbridge Risk Solutions Limited), to offer you products or services to enable you to comply with your legal obligations or otherwise support your business in accordance with your legitimate interest and for the purposes of paying a referral fee to us in accordance with the terms of our engagement with you
- Equal opportunities monitoring in relation to providing access to our services to comply with our legal obligations
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. Where the grounds for processing involve marketing to you, you will always have the option to object to us processing for this purpose.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing our services to you or your business), or we may be prevented from complying with our legal or regulatory obligations (such as to report financial impropriety in relation to anti-money laundering),
Change of purpose
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How We Use Particularly Sensitive Personal Information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information with your explicit written consent.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
Our obligations as an Accountancy Provider
We will use information relating to leaves of absence, which may include sickness absence or health, or disability status, to advise you in relation to statutory/state benefits to which you may be entitled and/or to assist you with any legal rights or obligations you may be required to comply with.
Do we need your consent?
Usually, we will approach you for your explicit consent to allow us to process certain particularly sensitive data. We will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent.
Information About Criminal Convictions
We do not envisage that we will hold information about criminal convictions for the majority of our customers.
We will only collect information about criminal convictions with appropriate consent if it is appropriate given the nature of the services we provide and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the initial engagement process to assess your suitability to act as a director of business and provide advice and guidance in relation to the same; or we may be notified of such information directly by you during the course of our engagement. We will use information about criminal convictions and offences to assess your suitability to continue to be engaged as a director of your business to enable us to provide advice and guidance as may be required from time to time.
We are allowed to use your personal information in this way to carry out our obligations during our engagement and in compliance with legal obligations imposed on the supply chain relating to atypical/temporary workers, personal service companies and independent contractors/consultants.
Automated Decision-Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may use some automated decision making in order for us to understand the information required from you in order for us to comply with our anti-money laundering obligations as we will use online search tools to assist us in the performance of Know Your Client and Identity Checking activities from time to time.
We may have to share your data with third parties, including third-party service providers and other entities in the Brookson Group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services, legal services, financial services. The following third-party service providers process personal information about you for the following purposes:
Brookson Legal Services Limited: | For the provision of legal support for the business during the course of your engagement with us. The reason for processing will be performance of a contract but we may also be share data to offer you products that may be of interest to you in which there is a legitimate interest to share. |
Brookson Financial Limited: | Auto enrolment and pension compliance activities as well as advice and guidance on mortgages, investments and protection products and services. There is a legitimate interest to share data for this purpose. |
RCAF VI Mallard Group Limited | Managerial oversight of our business, strategy and services. |
FCSA Institute of Chartered Accountants of England & Wales Solicitors Regulation Authority Financial Conduct Authority | For audit and regulatory compliance activities. There is a public interest to share data for this purpose and we do so to comply with the terms of our contracts with employees and customers. These audits and regulatory activities are intended to offer additional comfort to employees and customers that we act in compliance with legal and regulatory obligations. We share payslips, contracts of employment, grievances and disciplinary data, business data, accountancy and payroll processes and information, engagement letters along with internal processes and guidance. |
HMRC | For tax compliance activities. We have a legal obligation to share data for this purpose. |
Recruitment businesses | To enable them to manage the assignment on which you are engaged to provide services on our behalf and comply with their legal and regulatory obligations (including quarterly off-payroll worker reports to HMRC) in relation to the same. There is a legitimate interest to share data for this purpose, it is also referenced in our contracts as an obligation that we comply with. |
End clients | To whom you are engaged to provide services to enable them to manage your engagement; protect your health and safety at work; process working time and comply with their legal, regulatory and contractual obligations in relation to the same. There is a legitimate interest to share data for this purpose, it is also referenced in our contracts as an obligation that we comply with. |
Credit Safe / Lexis Nexis | To assist us with our anti-money laundering checks. We have a legal obligation to share data for this purpose, it is also referenced in our contracts as an obligation that we comply with. |
Solicitors and legal advisors | To provide legal advice and services to our business. Our solicitors include Lewis Silkin LLP, Littler Global, Reach Commercial Finance Limited (t/a Leonard Curtis) |
Kingsbridge Risk Solutions Limited | To support your business with insurance requirements in order for you to comply with best corporate governance or legal obligations. There is a legitimate interest to share data for this purpose. |
Zempler Bank | To provide banking services to your business which work seamlessly with our online services. There is a legitimate interest to share data for this purpose. |
Other banking providers / banking partners from time to time | To provide banking services to your business and which may work seamlessly with our online services. There is a legitimate interest to share data for this purpose. |
GoTo | For the provision of telecommunication services and recording facilities. |
SafeRec | To provide payslip reviewing and auditing services for group businesses to ensure they are calculated appropriately with details of our audits and reviews provided to recruitment businesses that we work with from time to time. We provide SafeRec with details of payslips, employee names, addresses and dates of birth, recruitment businesses that we work with, tax codes and ensure there are appropriate confidentiality provisions in place to protect the data. |
Accountants and auditors | We work with accountants such as EY, Grant Thornton and RSM to provide tax, accountancy and financial audits for our group businesses. We provide our accountants and auditors with details of payroll, employees, customers, tax references, addresses and dates of birth, litigation, customer queries and ensure there are appropriate confidentiality provisions in place. |
Fair Work Agency, ACAS, Employment Agency Standards Inspectorate | We share employee and customer data to comply with legal and regulatory obligations. Information can include contracts of employment, payroll information, tax codes, name, addresses and dates of birth |
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group as part of our regular operations and reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data, for back office support and legal support.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the Brookson Group; regulatory compliance activities (as a member of the Freelance and Contractor Service Provider Association (FCSA) and the Institute of Chartered Accountants in England and Wales); and recruitment businesses to support us with work finding opportunities and services.
Data Security
We have put in place measures to protect the security of your information and remain keen to comply with the requirements of ISO 27001. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Group Data Protection Officer.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data Retention
How long will you use my information for?
We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our data retention policy which is available from our Group Data Protection Officer (dpo@brookson.co.uk). 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations (where appropriate).
Rights of Access, Correction, Erasure, and Restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information to ensure it remains accurate and up to date
- Request erasure of some or all of your information which we hold on you, subject to us complying with our legal and regulatory obligations which may override your right to request erasure
- Right to request that we cease processing some or all of your information, in whole or in part, subject to our legal and regulatory obligations which may override your right to request that we either pause our processing activities or cease processing your personal data entirely
- Right to request that your data is transferred to a third party (portability) in the event that you look to use the services of a third party (such as if you chose to use another accountant or apply for a mortgage), we will share data relating to your engagement with us with such third party (for example, your new accountant or mortgage provider), upon request
- Right to object to some or all of your data no longer being processed by us (either temporarily or permanently). This will be subject to our legal and regulatory obligations which may override your right to request this, but we will ensure that such obligations and or/legitimate interest or ours (or others) are sufficiently compelling in order to override you rights in this regard
- If we use automated decision making or profiling you will be able to request manual/human intervention to ensure appropriate decisions are taken or advice provided
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to Withdraw Consent
Where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please respond to the point of contact from whom you received the last communication to which you consented to receive, or our Business Advisory Team. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, insofar that we do not have a legal obligation to do so. Please also note that in certain circumstances withdrawing consent may restrict us from performing our contractual obligations.
Data Protection Officer
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO by email at dpo@brookson.co.uk. 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.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the Business Advisory Team on 0345 058 1200
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to customerservices@brookson.co.uk.
Terms of Use
This page (together with the Connect Conditions of Use and any other documents referred to on it) tells you the terms of use on which you may make use of our website www.brooksonone.co.uk (‘our site’), whether as a guest or a registered user. Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.
Information About Us
www.brooksonone.co.uk is a site operated by Brookson Limited (“we”, “us”, “our”). We are registered in England and Wales as a private limited company. Our company number is 3128631 and we have our registered office at Brunel House, 340 Firecrest Court, Centre Park, Warrington, WA1 1RG. Our VAT number is 764688475.
Accessing Our Site
Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice (see below). We will not be liable if for any reason our site is unavailable at any time or for any period.
From time to time, we may restrict access to some parts of our site, or our entire site, to users who have registered with us. If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these terms of use.
You are responsible for making all arrangements necessary for you to have access to our site. You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms, and that they comply with them.
Prohibited Uses
You may use our site only for lawful purposes. You may not use our site:
- In any way that breaches any applicable local, national or international law or regulation.
- In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
- For the purpose of harming or attempting to harm minors in any way.
- To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards.
- To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.
You also agree:
- Not to reproduce, duplicate, copy or re-sell any part of our site.
- Not to access without authority, interfere with, damage or disrupt:
- any part of our site;
- any equipment or network on which our site is stored;
- any software used in the provision of our site; or
- any equipment or network or software owned or used by any third party.
Interactive Services
We may from time to time provide interactive services on our site, including, without limitation:
- Chat rooms.
- Bulletin boards.
Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).
We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.
The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not foolproof. Minors who are using any interactive service should be made aware of the potential risks to them.
Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.
Content Standards
These content standards apply to any and all material which you contribute to our site (‘Contributions’), and to any interactive services associated with it. You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any contribution as well as to its whole.
Contributions must:
- Be as accurate as possible (where they state facts).
- Be genuinely held (where they state opinions).
- Comply with applicable law in the UK and in any country from which they are posted.
Contributions must not:
- Contain any material which is defamatory of any person.
- Contain any material which is obscene, offensive, hateful or inflammatory.
- Promote sexually explicit material.
- Promote violence.
- Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
- Infringe any copyright, database right or trade mark of any other person.
- Be likely to deceive any person.
- Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
- Promote any illegal activity.
- Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.
- Be likely to harass, upset, embarrass, alarm or annoy any other person.
- Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.
- Give the impression that they emanate from us, if this is not the case.
- Advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.
Uploading Material to Our Site
Whenever you make use of a feature that allows you to upload material to our site, or to make contact with other users of our site, you must comply with the content standards set out above. You warrant that any such contribution does comply with those standards, and you indemnify us for any breach of that warranty.
Any material you upload to our site will belong to you exclusively, will not infringe the trade marks or copyright of third parties and will be considered non-confidential and non-proprietary. We reserve the right to use, copy, distribute and disclose to third parties any such material for any purpose. We also have the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to our site constitutes a violation of their intellectual property rights, or of their right to privacy.
We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by you or any other user of our site. We have the right to remove any material or posting you make on our site if, in our opinion, such material does not comply with the content standards.
Intellectual Property Rights
We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may print off one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.
You must not use any part of the materials on our site for commercial purposes without obtaining a licence to do so from us or our licensors.
If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
Reliance on Information Posted
Commentary and other materials posted on our site are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to our site, or by anyone who may be informed of any of its contents.
Our Site Changes Regularly
We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.
Our Liability
The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, other members of our group of companies and third parties connected to us hereby expressly exclude:
- All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.
- Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:
- loss of income or revenue;
- loss of business;
- loss of profits or contracts;
- loss of anticipated savings;
- loss of data;
- loss of goodwill;
- wasted management or office time; and
- for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable.
This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.
Information About You and Your Visits to Our Site
We process information about you in accordance with our privacy policy. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.
Viruses, Hacking, and Other Offences
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack.
By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.
Linking to Our Site
You may link to our home page subject to our prior consent, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
You must not establish a link from any website that is not owned by you.
Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. We reserve the right to withdraw linking permission without notice.
The website from which you are linking must comply in all respects with the content standards.
If you wish to make any use of material on our site other than that set out above, please address your request to customerservices@brookson.co.uk
Links from Our Site
Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them.
Suspension and Termination
We will determine, in our discretion, whether there has been a breach of this policy through your use of our site. When a breach of this policy has occurred, we may take such action as we deem appropriate.
Failure to comply with this policy constitutes a material breach of the terms of use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:
- Immediate, temporary or permanent withdrawal of your right to use our site.
- Immediate, temporary or permanent removal of any posting or material uploaded by you to our site.
- Issue of a warning to you.
- Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
- Further legal action against you.
- Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.
We exclude liability for actions taken in response to breaches of this policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.
Jurisdiction and Applicable Law
The English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to our site although we retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country. These terms of use are governed by English law.
Variations
We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.
Your Concerns
If you have any concerns about material which appears on our site, please contact customerservices@brookson.co.uk.
Modern Slavery Statement
Brookson One (and each of its brands using this trading style named below) is committed to combatting slavery and human trafficking. We regularly review and improve our practices and are keen to work with our end user hirers, recruitment agencies and partners, technology collaborators and staff to eradicate these unacceptable practices.
It is essential that those we engage with understand and appreciate the standard of business conduct expected of any company that we do business with and we will only seek to engage with reputable organisations.
Brands covered by this statement:
The following subsidiaries of the Brookson Group trade as Brookson One and are covered by the scope of this statement:
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Brookson Solutions Limited |
Brookson CIS Solutions Limited |
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Brookson Limited |
Brookson Construction Limited |
Our Business
Our business provides an effective worker engagement solutions to recruitment agencies and end clients. The contingent worker services that we offer facilitate the engagement between temporary workers and public or private organisations in the United Kingdom.
Our Supply Chain
Our supply chains include the below entities working within the medical sector:
- Recruitment Businesses
- Public and private sector hirers
- Locum/contingent labour/temporarily engaged professionals
- Interoperability partners
- Suppliers
Our policies on slavery and human trafficking
Our Modern Slavery Policy reflects our ongoing commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our business or supply chains.
Due diligence processes for slavery and human trafficking
We undertake ‘Right to Work Checks’ and maintain a heightened ‘Know Your Client’ process for all overseas nationals looking to secure work in the UK without discriminating against any workers on the basis of their race, nationality, caste, creed or colour.
We have processes and systems in place to:
- Identify and assess potential risk areas in our supply chains with the use of an escalation process through our Legal & Compliance Team.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Report potential instances of modern slavery and human trafficking.
- Protect whistle blowers.
We undergo a ‘Ways of Working’ consultation with everyone engaging in our umbrella and construction entities to ensure the worker is comfortable operating in such a manner. As part of our process, we ensure that no one is under undue influence from any third parties to provide services and ensure that individuals are entering into contracts under their own freewill.
Supplier adherence to our ethics
We have zero tolerance to slavery and human trafficking and we are keen to ensure that all those in our supply chain comply with our ethics.
As part of the Brookson Group, we benefit from the dedicated Legal & Compliance Team, which consists of senior personnel from legal, financial services and accountancy businesses within the Brookson Group and this team will field any queries or comments from suppliers, customers, employees or regulators in relation to our approach to combatting slavery and human trafficking.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide ongoing training to our staff. Training is also provided to all new employees to ensure they are aware of our stance on preventing slavery and human trafficking within the businesses and supply chains and how to identify if someone is being trafficked.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 30 December 2025.
Approved by the directors and shareholders: Brookson Group Limited
Signed by: Matthew Fryer
Managing Director – UK & Ireland
For and on behalf of Brookson One
Gender Pay Eqality
Complaints Procedure
If you are dissatisfied with our services for any reason, please speak to a Customer Service representative in the first instance and they will try to resolve the issue where possible. If you do not feel that your matter has been adequately dealt with, please follow the formal complaint process below:
- The complaint should be put in writing to complaints@brookson.co.uk marked Complaint in the subject box detailing exactly what your complaint is and how you feel it should be resolved.
- On receipt of the complaint in writing, this will then be logged as a formal complaint and an acknowledgement email sent to you
- A senior member of our Customer Relations Team will then contact you to resolve your complaint and offer a solution where appropriate.
- In the unusual event that they are unable to resolve the complaint to your satisfaction, you can appeal in writing to complaints@brookson.co.uk marked with Complaint Appeal – FAO Customer Relations Manager in the subject box. Your complaint will then be reviewed and you will be contacted further until full resolution of your complaint.
- Once the complaint is resolved to your satisfaction the complaint will be filed as resolved.
- Notes are updated on your personal file to ensure that all of the above has been met.
Tax Strategy
This document sets out the Group’s approach to risk management and governance arrangements in relation to UK taxation. This document has been published to comply with Schedule 19 of Finance Act 2016.
It has been approved by the Board of Directors of People2.0 Umbrella Holding UK Limited (including Brookson Group) and is effective for its accounting period commencing 1st January 2024. This strategy will be re-approved and republished at least annually.
People2.0 Umbrella Holding UK Limited (including Brookson Group) is committed to:
- Following all applicable laws and regulations relating to its tax activities.
- Maintaining an open and honest relationship with the tax authorities based on collaboration and integrity.
- Ensuring that the tax strategy adopted is consistent with the Group’s overall strategy.
- Applying diligence and care in our management of tax risks and ensuring that our tax governance is appropriate.
Risk Management
Tax risks are assessed on a case by case basis, allowing the Group to arrive at well-reasoned conclusions on how each individual risk should be managed. Where there is uncertainty in how the relevant tax law should be applied, external advice may be sought to support the Group’s decision- making process.
The Group Finance Director has responsibility for tax at Board level and tax is regularly discussed by the Internal audit committee. The Group’s tax policy, which is approved by the Board, drives the Group’s behaviour with regards to taxation and tax risk.
The day to day management of taxes is the responsibility of the wider finance team. This team includes professionals with recognised professional qualifications and we continue to invest in their training and development. We operate under defined processes and controls in order to manage tax risks on a day to day basis.
Tax Planning
- The Group has clearly defined lines of responsibility for its tax affairs, with decisions being taken in line with the Group’s tax authority thresholds, ensuring that they are taken at an appropriate level.
- The Group’s tax planning is driven by the commercial needs of the business and anticipated future developments. Where alternative routes exist to achieve the same commercial results, the most tax efficient approach in compliance with all relevant laws will be followed.
- The commercial needs of the business will in no circumstances override compliance with all applicable laws and regulation. The tax function is therefore involved in decision making and provides appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made.
- In cases where the tax guidance is unclear or the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice may be sought to support the Group’s decision- making process.
Assessing Level of Risk
When reviewing the tax risks associated with a specific decision or action, the Group ensures that the following are considered:
- The legal and fiduciary duties of directors and employees.
- The requirements of any related internal policies or procedures.
- The maintenance of the Group’s corporate reputation, having particular regard to the way we interact with the communities around us.
- The tax benefits and impact on the Group’s reported result compared to the potential financial costs involved, including the risk of penalties and interest.
- The wider consequences of potential disagreement with tax authorities, and any possible impact on relationships with them.
Approach Towards Dealings with HMRC
The Group is committed to the principles of openness and transparency in its approach to dealing with HMRC and in particular the Group commits to:
- Adopting open and collaborative professional relationships at all times with HMRC.
- Engage in full, open and early dialogue with HMRC to discuss tax planning, strategy, risks and significant transactions.
- Make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion.
- Seek to resolve issues with HMRC in real time and before returns are filed if possible, and where disagreements arise work with HMRC to resolve issues by agreement where possible.
- Be open and transparent about decision-making, governance and tax planning.
- Reasonably believe that transactions are structured to give a tax result which is not inconsistent with the economic consequences (unless specific legislation anticipates that result), nor contrary to the intentions of Parliament.
- Interpret the relevant laws in a reasonable way, and ensure transactions are structured consistently with a co-operative relationship.