Privacy & GDPR Policy

At Diablo Initiative, we are committed to protecting your personal data and ensuring your privacy is respected. This policy outlines how we collect, use, and safeguard your information in line with the UK General Data Protection Regulation (UK GDPR).

Who We Are

Diablo Initiative provides payroll and CIS services to UK-based businesses. Our operations involve processing personal data for clients, subcontractors, employees, and other parties as necessary to fulfil our services.

Contact Details:
Phone: 03330 417589
Email: info@diablo-initiative.com

What Data We Collect

We may collect and process the following types of personal data:

• Full names and contact details (phone numbers, email addresses)

• National Insurance numbers and UTRs (Unique Taxpayer References)

• Bank details for payment processing

• Employment status and payroll records

• Timesheet data and work assignment history

• Copies of identification or right-to-work documents

How We Use Your Data

We process your data to:

• Administer payroll and CIS services

• Verify subcontractors under HMRC rules

• Submit reports and returns to HMRC

• Issue payslips, remittances, and tax documents

• Respond to queries and provide support

• Maintain accurate financial and compliance records

Lawful Basis for Processing

Our processing is based on one or more of the following lawful grounds:

• Contractual necessity – to deliver services as agreed

• Legal obligation – to comply with HMRC and employment law

• Legitimate interest – to manage and improve our operations

• Consent – where applicable, and only when explicitly given

Data Sharing

We only share data when necessary, and only with:

• HMRC and other regulatory authorities

• Trusted payroll software providers and IT platforms

• Financial institutions for payment processing

• Professional advisers (e.g. accountants or legal consultants)

We do not sell or trade your personal data under any circumstances.

Data Retention

We retain payroll and compliance records for a minimum of six years, or as required by HMRC and other legal obligations. Once data is no longer needed, it is securely deleted or anonymised.

Data Security

We implement appropriate technical and organisational measures to safeguard your data, including:

• Encrypted communications and secure storage

• Access controls and user authentication

• Regular data audits and system reviews

Your Rights Under UK GDPR

You have the right to:

• Access the personal data we hold about you

• Request correction of inaccurate data

• Request erasure of your data (subject to legal obligations)

• Object to or restrict certain types of processing

• Request transfer of your data to another service

• Withdraw consent at any time (where applicable)

To exercise these rights, contact us at:
info@diablo-initiative.com

Complaints

If you are not satisfied with how we handle your data, you have the right to lodge a complaint with the UK’s Information Commissioner’s Office (ICO):