Privacy & Modern Slavery Policy


This privacy statement describes how R W Armstrong & Sons Ltd collects and uses personal information about you in accordance with the General Data Protection Regulation (GDPR).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For applicable privacy legislation, the Data Controller is R W Armstrong of Armstrong House, Aldermaston Road, Sherborne St John, Basingstoke, Hampshire, RG24 9JZ.

Questions regarding this policy should be directed to our Data Protection Compliance Officer. The Data Protection Compliance Officer is responsible for ensuring compliance with the Act (whilst applicable), the regulations and with this policy. That post is held by Laura Hamblin, 01256 851854, Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Officer.

1. Data Protection Principles

R W Armstrong is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
• Processed lawfully, fairly and in a transparent manner in relation to individuals;
• Collected for a specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes which they are processed;
• Accurate and, is kept up to date. Every reasonable step must be taken to ensure that any personal data, having regard to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. Lawful Purpose

• All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interest, public task or legitimate interest (see ICO Guidance for more information);
• Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data;
• Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems are in place to ensure revocation is reflected accurately in the company’s systems.

3. General Provisions

• This statement applies to all personal data processed by R W Armstrong;
• The Data Protection Officer shall take responsibility for the Company’s ongoing compliance with this statement.

4. What information do we collect from or receive about you?

Email Address
Telephone Number – home and mobile
Past Professional relationship with R W Armstrong & Sons Ltd
Feedback and testimonials on our service
Email analytics
Project Photography and correspondence
Referee details
T&C’s of offer of employment
Qualifications, training, skills, experience, employment history
Benefits & entitlements
Details of professional memberships
Driving license checks
DBS checks
Identification for Right to Work (i.e. Passport).

5. How do we collect this data?

Application forms
Agency summaries
Database checks
Information obtained from documents provided
Correspondence during the interview process
We may use social media to validate the information on their CV, i.e. LinkedIn, Glassdoor or other relevant social media platforms.

6. How do we use the information?

We use the information held about you in the following ways:

• To carry out our obligations arising from any contracts entered into between you and us
• To contact you if we wish to use your information for a purpose not set out in this policy
• To further improve our services and manage external relationships effectively
• To promote our services
• To ensure we are complying with our legal obligations
• For analysis; diversity & inclusion and equal opportunities monitoring.

7. Disclosure of your information

We will share your information with the following categories of selected third parties:
• Suppliers and sub-contractors for the performance of any contract we enter into with you. All third-party suppliers are to take appropriate security measures to protect personal information in line with our policies.

8. Security

• The company shall ensure that personal data is stored securely using modern software that is kept up to date;
• Access to personal data shall be limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information;
• When personal data is deleted it will be done safely such that the data is irrecoverable;
• Appropriate back-up and disaster recovery solutions are in place.

9. Basis for processing your personal data

Where we disclose your personal data to third parties

• In certain situations, we may ask for your permission before sharing your information with third party service providers. In such situations, we will be relying on your permission for the basis of sharing that information. You have the right to withdraw your permission for us to share your information at any time.
• In other situations, where we collect information about you from third parties, we rely on either a legal right to process that information or our legitimate interests for collecting that information set out in this policy.

10. Data Minimisation

R W Armstrong shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed.

11. Accuracy

• We shall take responsible steps to ensure personal data are accurate;
• Where necessary for the lawful basis on which data is processed, steps have been put in place to ensure that personal data is kept up to date.

12. Change of purpose

We will only use your information for the purpose in which it was collected. If we need to use for another unrelated purpose, we will notify you and explain the legal basis under which this change has occurred.

13. Where we store your personal data

Electronic versions of the information you provide to us or we collect about you is stored on our servers, or securely on third-party password protected sites.

We have taken appropriate measures to ensure our servers are safe and secure including restricting access to the server room/password protecting information stored on the servers/installing antivirus and firewall software.

14. How long we will store your personal data for

• To ensure that personal data is kept for no longer than necessary, the Company has put in place an archiving policy for each area in which personal data is processed and review this process annually;
• The archiving policy considers what data should/must be retained, for how long and why.
• Unsuccessful candidates’ data will be deleted after 12 months
• Successful candidates’ data will be transferred to their personnel file and kept in accordance with our internal retention policy.

15. Your rights

You have the following rights in connection with your personal information held by us:

• You may request information on what personal data we hold and access to it;
• You may request we rectify any data we hold about you (i.e. if the data is incorrect), erase that data or restrict the types of processing we carry out in respect of that data;
• You may request we provide you with the personal data we hold about you in order that you can use it for your own purposes across other services.

16. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.

17. Changes to our privacy policy

We reserve the right to update this statement at any time. You will only be notified when a substantial change is made. Any changes will become effective immediately and will apply to personal data collected on or after such date.


STATEMENT FY 2018/2019


R W Armstrong & Sons Ltd is a family firm of 60 years standing, specialising in the new build and refurbishment of period and country homes, as well as townhouses and listed properties. From heavily engineered works, through to final finishes and maintenance. We employ a direct workforce of 68 tradesmen and take on new apprentices each year. Our five offices are ideally positioned throughout London and the South, combining a range of local expertise, as well as a robust network of subcontractors.

R W Armstrong & Sons Ltd is committed to understanding modern slavery risks, and ensuring that there is no modern slavery within our own business or supply chains. Modern slavery is ‘a hidden crime that encompasses slavery, servitude, forced labour and human trafficking’. Modern slavery has no place in our business or supply chains and we take a zero-tolerance approach to it.

Hidden labour exploitation is exploitation of job applicants or workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators; with victims, if they perceive themselves as such, reluctant to come forward.

Our employees are made aware of the risks of slavery and human trafficking and are expected to report any concerns. Management will be expected to act upon them.

Our Supply Chain

We are committed to ensuring that there is no slavery or human trafficking in our supply chains and it is our policy to implement effective and robust controls to ensure this is not taking place. We are in the process of introducing supplier questionnaires to ensure that all of our products are responsibly sourced.

Our Policies in relation to Modern Slavery and Human Trafficking
R W Armstrong & Sons Ltd will not knowingly use any individual or organisation to source and supply workers using practices of forced labour or human trafficking for labour exploitation. We will report any evidence or suspicion of cases or hidden third party labour exploitation to the Gangmasters and Labour Abuse Authority immediately. Failure by managers and leaders of the company, third party labour providers or organisations in the labour supply chain to act upon concerns of worker maltreatment, coercion or harassment will be regarded as potential gross misconduct and will be managed accordingly through the relevant disciplinary process.

Whistleblowing Policy – R W Armstrong & Sons Ltd actively encourages all its employees to report any concerns that raise suspicions related to human trafficking both inside our organisation and through the supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. R W Armstrong & Sons Ltd’s procedure is designed to make it easy for workers to make disclosures without fear of retaliation.

Recruitment – R W Armstrong & Sons Ltd will not use any individual or organisation to source and supply workers using practices of forced labour, human trafficking for labour exploitation, payment for work finding services or any work-related exploitation such as forced use of accommodation. R W Armstrong & Sons Ltd will confirm (through their own recruiting processes or through recruiting processes of third party agencies) that workers are not subject to any of the above practices and will report any evidence or suspicion of cases of hidden third-party labour exploitation to the Gangmasters and Labour Abuse Authority immediately.

Agency Workers – R W Armstrong & Sons Ltd only uses specified reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. Regular audits of each agency as well as audits of new agencies beginning to supply R W Armstrong & Sons Ltd are part of the processes by which risks of slavery and human trafficking are addressed in relation to agency workers. All agencies used for temporary labour in the manufacturing of our products are licenced by the Gangmasters and Labour Abuse Authority. We actively check these and audit them on a regular basis.

Training – R W Armstrong & Sons Ltd provides information on “Hidden Labour Exploitation” to our workforce through a variety of formats including staff presentations during induction and training periods and through internal auditing processes. The company also actively encourages workers to report cases of hidden third-party labour exploitation, provides the means to do so and investigates and acts upon reports appropriately.

Business Integrity – R W Armstrong & Sons Ltd clearly communicates to employees the actions and behaviours expected of them when representing the organisation. The organisation strives to maintain the highest standard of employee conduct and ethical behaviour when managing its supply chain.

Due Diligence
We are in the process of undertaking due diligence when considering taking on new suppliers and we will regularly review our existing suppliers and ethical standard across the business. We will never knowingly accept products from suppliers who exploit the people or natural resources within their environment.

Continuous Monitoring
R W Armstrong & Sons Ltd takes a zero-tolerance approach to slavery and we are committed to ensuring that operations and supply chains are free from slavery or human trafficking.

Every employee will be familiar with our Ethical standards and policies to ensure no slavery occurs within the business and are encouraged to report any potential breaches. Our statement is visible for all staff to view on the company’s website, intranet and from the HR department, as well as being provided during induction.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, has been approved by the directors of R W Armstrong & Sons Ltd and will be reviewed at least once annually.