Native is a trading name of Native Places Limited.
This policy is effective from and was last revised on 1st September 2023. The next review date is 1st March 2024 or first working day thereafter.
This policy explains how Native protects and processes your personal information.
‘Your personal information’ means any information about you that you or third parties provide to us, or we produce in relation to our services offered or provided to you.
Where we provide products or services under contract with an organisation (for example your employer), that organisation controls the information processed by Native on your behalf until they transfer it to us, upon which point Native assumes responsibility to process your data.
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
1. Native’s Privacy Principles
2. What information Native collects about you
The personal information we collect depends on the products and services you have, how you use them, how you made contact, enquired or booked and through which channel, partner or third party this was done. Depending on these factors, Native could hold any of the below personal information about you:
Personal contact details such as a person’s name, title, home address, email address(es),
Other personal details such as a person’s gender, age, date of birth, place of birth, nationality,
Work contact details such as employer name, work address, job title, email address(es),
Other work related details such as personnel Id, work grade, employment history, salary,
Government issued identifiers such as passport, national insurance number, drivers licence,
Financial details such as bank account details, payment card details, credit scores, account debt
Sensitive personal data such as health conditions, but only when required to plan appropriately
Criminal offence data if and when supplied by third parties such as referencing agencies or
Media content such as photographs, images, video or audio recordings, printed goods used for
Social media content if provided by you in accordance and acceptance of this policy such as
User account details such as username, password (encrypted), security questions, security
Contact and marketing preferences such as whether you have provided or withdrawn consent /
Job applicant details such as CVs, covering letters and any supporting documents
Photos, video files (such as CCTV coverage) or documents required to manage our properties
Telephone call data such as voice data for calls recorded for quality or training purposes or
SMS / IM messages received by apps we use for sales or operational purposes
3. Why Native collects this information and how we use it
Why we collect personal information and how we use the information we collect depends in part on which services you enquire about, order or use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you [as well as the lawful basis for processing for each].
4. How we store and secure information we collect
Native uses a multi-data centre infrastructure hosting service in the United Kingdom for all personal information we collect, whether on our file network, websites or apps. This infrastructure is ISO 27001 certified and provides enterprise class resilience and security.
Access to our network and apps is controlled by an enterprise level 2 Factor Authentication solution
Our websites have up to date SSL certificates that provide robust authentication and encryption, to reassure you that your data and transactions are secure.
We restrict access to personal information so that only controllers and processors of the data that need it for legitimate business purposes have access to it.
We also have data use policies and training in place to ensure all our staff are responsible with your data and understand their obligation to protect it.
5. How long we keep information
How long we keep information we collect about you depends on the type of information and the type of interaction you have had with Native, as specified by the retention periods below. Prior to or at the point of the retention period being met, we will either delete or anonymise your information as applicable. Where more than one of the below categories applies to a piece of data, the longest retention period shall be enforced.
Sign-ups for news, offers or marketing campaigns – If you have provided your contact details and confirmed that you have provided consent to receive news, offers or marketing campaigns, we will retain your personal information for no longer than 5 years from the point you last expressed an interest/opened a communication without unsubscribing/provided consent/contacted us/subscribed or unsubscribed. We retain information derived from cookies and other tracking technologies for no longer than 5 years.
Personal Information related to Enquiries and Orders – If you have made an enquiry about or order for products or services or a third party has done so on your behalf, we will retain your information for no longer than 7 years from the point of your last enquiry or order.
Billing – If you have been billed by Native for any products or services, we will retain your information for no longer than 7 years from the point of billing of your last invoice.
Account Information – We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our products and services.
Client contracts – If you’re an employee of a corporate client that specifies in our contract that data must be retained for reporting purposes on their behalf for a particular period, we will comply with that length of time where possible and where they have confirmed their responsibility as data controller in that regards.
Job Applicant details – CVs, covering letters, application forms and interview notes for unsuccessful candidates will be retained for no longer than 1 year. Successful candidates will have these files transferred to their personnel file, for which our retention period will not be covered by this document.
Other files and emails – We retain active, undeleted electronic files and emails for a period of no longer than 7 years, unless they have been identified as business critical and set to not be deleted.
Complaints – We retain complaints and responses to them for no longer than 6 years from closure.
Telephone call and SMS / IM data – We retain recorded calls and messages no longer than is required for quality, training or legal reasons or will retain no longer than 1 year, whichever is greater.
In other cases we’ll store personal information for the periods needed for the purposes for which the information was collected or for which it is to be further processed. And sometimes we’ll keep it for longer if we need to by law. Otherwise we delete it.
6. How Native shares information we collect
We only share your personal information where it is necessary for us to do so for legitimate business purposes, or if that is not the case, when you have provided consent for us to do so. We will only share personal information with other companies in our supply chain that we have verified are handling your details securely.
We do use third party service providers to process personal information on our behalf for the kinds of purposes set out below:
Where we use another organisation, we still control your personal information.
If there’s a change (or expected change) in who owns us or any of our assets, we might share personal information to the new (or prospective) owner. If we do, they’ll have to keep it confidential.
7. How Native transfers information we collect internationally
8. Your rights and other important privacy information
Native is committed to compliance with Data Processing Laws and respecting your privacy. “Data Processing Laws” means (a) the Data Protection Act 2018 (DPA 2018) and/or any laws or regulations implementing the General Data Protection Regulation (UK GDPR); and/or any corresponding or equivalent national laws or regulations; and any applicable laws replacing, amending, extending, re-enacting or consolidating any of the above DP Laws from time to time; For the purposes of the Data Processing Laws Native is the data controller.
GDPR provides you with the below rights concerning the processing of your personal data. These are listed below:
In addition, the Data Processing Laws provide you with the right to withdraw consent for the processing of your data for data upon which the basis for processing is consent, which you can do via the process mentioned below.
To find out more information about these rights and our obligations, please visit the Information Commissioner’s Office website https://ico.org.uk
9. How you can access and control your information held by Native
If you have any questions or require details related to the personal information we hold about you or wish to exercise any of your rights outlined in this policy, get in touch with our Data Protection Officer by
Or write to us at:
Data Protection Officer
11th Floor, Newcombe House
45 Notting Hill Gate
If you are requesting access to your information, by law you will need to provide the below in your communication for us to be able to legally issue a full response to your request to access information, which we will do within one calendar month, free of charge.
If you want to make a complaint on how we have handled your personal information, please contact our data protection officer who will investigate the matter and report back to you.
If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the data-protection regulator in the country where you live or work. For the UK, that’s the Information Commissioner’s Office – https://ico.org.uk