Legal & Compliance
Privacy Policy
Version 2.6.0 | Effective: March 25, 2026
Privacy at a Glance
- ✓We collect only data necessary for staffing services
- ✓Your data is encrypted and stored securely in UK/EU
- ✓We never sell your personal data to third parties
- ✓You have full control over your data (access, delete, port)
- ✓AI assistants help but don't make critical decisions
- ✓Compliant with UK GDPR & Data Protection Act 2018
1. Who We Are
Data Controller: Opus Platforms Limited (trading as "Opus")
Company Number: 16856935
Registered Office: Unit 314b, 566 Cable Street, London, E1W 3HB, United Kingdom
Employer PAYE Reference: 120/BF05099
HMRC Accounts Office Reference: 120PP03666762
Email: compliance@opusplatforms.co.uk
Data Protection Contact: compliance@opusplatforms.co.uk
ICO Registration: ZC090582 (verify at ico.org.uk)
Opus is a PAYE staffing agency that connects UK employers with qualified gig workers through our web platform and WhatsApp. This policy explains how we collect, use, and protect your personal data in compliance with UK GDPR and the Data Protection Act 2018.
2. Data We Collect
2.1 Worker Registration
| Data | Purpose | Legal Basis |
|---|---|---|
| Full name | Identity, contracts, payroll | Contract |
| Email address | Account access, notifications | Contract |
| Phone number (E.164) | SMS verification, WhatsApp shifts | Contract |
| Home postcode | Shift matching by location | Contract |
| Password (hashed) | Account security | Contract |
| Role preferences | Job recommendations | Legitimate interest |
| Language preference | Communicating in your preferred language | Consent |
2.2 Identity Verification (Right to Work)
| Data | Purpose | Legal Basis |
|---|---|---|
| Passport / ID documents | UK Right to Work verification | Legal obligation (Immigration Act 2016) |
| Biometric data (facial scan) | RTW biometric matching via Home Office-certified IDSP; raw biometric data is processed by the IDSP only and is not retained by Opus | Substantial public interest (Article 9(2)(g) UK GDPR; DPA 2018, Schedule 1, Part 2, Para 6, preventing unlawful employment); explicit consent is also collected via Document 6 as an additional safeguard. Article 6(1)(c) legal obligation applies to the RTW check. |
| National Insurance number | PAYE payroll, tax reporting | Legal obligation (HMRC) |
| Visa type & restrictions | Student hour limits, work eligibility | Legal obligation |
| Share code (non-UK citizens) | Home Office RTW verification | Legal obligation |
Student Visa Compliance
If you hold a student visa, we automatically enforce 20-hour/week limits during term time and 40-hour/week during vacations. This is a legal requirement under UK immigration law.
2.3 DBS Background Checks
| Data | Purpose | Legal Basis |
|---|---|---|
| Personal details for DBS | Criminal record disclosure check | Consent (Article 6(1)(a)) + employment obligations (Article 9(2)(b) UK GDPR; DPA 2018, Schedule 1, Part 1, Para 1) |
| DBS certificate number | Compliance verification for roles | Legitimate interest |
| DBS Update Service status | Ongoing monitoring (with consent) | Consent |
2.4 Employment & Attendance
| Data | Purpose | Legal Basis |
|---|---|---|
| GPS coordinates (clock-in/out) | Verify attendance at work site | Consent + Legitimate interest |
| Shift times & attendance | Calculate pay, generate timesheets | Contract |
| Performance ratings | Quality assurance, employer feedback | Legitimate interest |
| Training & professional certifications (e.g., SIA, CSCS, driving licences) | Compliance, skill verification, role eligibility | Contract |
2.5 Financial Data
| Data | Purpose | Legal Basis |
|---|---|---|
| Bank account details | Salary payments via BACS | Contract |
| Tax codes | PAYE deductions | Legal obligation |
| Pension enrolment | Auto-enrolment compliance | Legal obligation |
| Payment history | Payslips, P60s, earnings records | Contract + Legal obligation |
2.6 Employer Data
| Data | Purpose | Legal Basis |
|---|---|---|
| Company name & registration | Account setup, invoicing | Contract |
| Business contact details | Service delivery, support | Contract |
| Site addresses & geofences | Worker attendance verification | Contract |
| Billing & payment info | Invoice processing | Contract |
2.7 Automatically Collected
| Data | Purpose | Legal Basis |
|---|---|---|
| Login/session data | Security, fraud prevention | Legitimate interest |
| Device/browser info | Technical support, compatibility | Legitimate interest |
| Usage analytics (if consented) | Platform improvement | Consent |
| AI interaction logs | Audit trail, service improvement | Legitimate interest |
| AI tool execution audit logs | Governance, compliance, safety auditing | Legitimate interest |
| AI approval records | Human oversight of AI-proposed high-impact actions | Legitimate interest |
3. How We Use Your Data
We process your data for these purposes:
| Purpose | Legal Basis | Details |
|---|---|---|
| Provide staffing services | Contract | Match workers to shifts, process assignments |
| Verify identity & RTW | Legal obligation | Immigration Act compliance |
| Process payroll & taxes | Contract + Legal | PAYE, NI, pension contributions |
| Send shift notifications | Contract | WhatsApp/SMS/email alerts |
| Verify attendance | Legitimate interest | GPS clock-in within geofence |
| Generate timesheets | Contract | Calculate hours for payment |
| Comply with AWR | Legal obligation | Track 12-week threshold |
| Platform Assistant queries | Consent + Contract | AI-powered shift/compliance help |
| Fraud prevention | Legitimate interest | Detect timesheet manipulation |
| Improve services | Legitimate interest | Analytics, feature development |
| AI governance & oversight | Legitimate interest | Internal review and human approval of AI-proposed high-impact actions via Ops Approval Workbench |
| AI model improvement | Legitimate interest | De-identified data used to train intent routing and safety classification models (opt-out available - see §4.6) |
4. AI Platform Assistant
How AI Works on Opus
Opus provides AI-powered assistants via web chat and WhatsApp to help you find shifts, check compliance status, and manage your work. Here's what you need to know.
4.1 What AI Can Do
- Workers (27 tools): Browse shifts, check earnings, view compliance status, manage availability
- Employers (30 tools): View shift fill rates, check worker compliance, approve timesheets
- All users: Get instant answers to platform questions 24/7
4.2 What AI Cannot Do
Critical Decisions Are Always Human/Rule-Based
- AI does NOT calculate your pay (deterministic payroll system)
- AI does NOT determine your compliance status (rule-based RAG system)
- AI does NOT approve shift assignments (first-valid-wins or employer approval)
- AI does NOT make hiring/firing decisions
4.3 Data Processing
- Queries processed by: Anthropic (Claude) under strict data processing agreements
- Data shared: Your query text, user role, relevant context (shift data, compliance status)
- Data NOT shared: Passwords, full bank details, biometric data
- Translation: If you set a language preference, platform communications (e.g., WhatsApp notifications) are translated using AI processing by our LLM providers
- Retention: AI queries logged for 2 years for audit/improvement
4.5 AI Governance & Human Oversight
Opus operates a tiered AI governance framework ensuring appropriate human oversight for all AI-assisted actions:
| Tier | Risk Level | Examples | Safeguard |
|---|---|---|---|
| Tier 0 | Read-only | Browse shifts, view earnings | Full audit logging |
| Tier 1 | Low-write | Update availability, create support tickets | User confirmation + audit |
| Tier 2 | High-impact write | Bulk shift cancellations, timesheet approvals, compliance overrides, user suspensions | Human ops approval required before execution |
| Tier 3 | Prohibited | Pay calculation, compliance determination, assignment allocation | AI cannot perform - deterministic systems only |
High-impact actions (Tier 2) are never executed automatically. They are proposed by the AI system and routed to the Ops Approval Workbench, where an authorised Opus team member must review and explicitly approve before execution. All AI tool executions - including approvals and rejections - are recorded in a permanent audit log retained for 6 years in accordance with UK employment law and ICO accountability obligations.
4.6 Model Training & Improvement
We use de-identified and anonymised interaction data to improve our internal AI models for:
- Intent routing: Understanding what users are asking (e.g., "show my shifts" vs "check my pay")
- Safety classification: Detecting and routing high-risk requests to human review
- Tool extraction: Improving accuracy of structured parameter extraction from natural language
Model Training Safeguards
- All PII is stripped before any data enters training pipelines
- Data Protection Officer (DPO) approval required before each training cycle
- Data Protection Impact Assessment (DPIA) maintained and reviewed bi-annually
- No biometric, financial, or identity document data is ever used for training
- Third-party LLM providers (Anthropic) are contractually prohibited from training on Opus data
Opt-out: You may opt out of your interaction data being used for model training at any time by contacting compliance@opusplatforms.co.uk or via Account Settings → Privacy → AI Data Preferences. Opting out does not affect your access to AI features.
4.7 Your Controls
You can opt out of AI features by contacting support. Core platform functionality remains available without AI assistance.
6. International Transfers
Your data is primarily stored in UK/EU AWS regions. Some services involve transfers outside the UK:
| Service | Destination | Safeguard |
|---|---|---|
| WhatsApp (Meta) | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
| Stripe | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
| Anthropic | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
| HubSpot | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
| Twilio | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
| Xero | Australia/UK | SCCs + GDPR DPA |
| Freshdesk | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
| eSignatures.io | UK/EU | UK adequacy (EEA); SCCs as fallback |
| PagerDuty | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
| Slack | USA | UK Extension to EU-US DPF (if certified); SCCs or UK IDTA as fallback |
SCCs = Standard Contractual Clauses approved by the UK ICO. Request copies at compliance@opusplatforms.co.uk
7. Data Retention
| Data Type | Retention Period | Reason |
|---|---|---|
| Account data | Duration of account + 6 years | Legal claims, tax records |
| Right to Work documents | 2 years after employment ends | UK Immigration Act requirement |
| Payroll & tax records | 7 years | HMRC statutory requirement |
| Attendance records | 6 years | Employment law, payroll disputes |
| Contracts (signed) | 6 years after termination | Limitation Act 1980 |
| DBS certificates | 6 months after verification | DBS Code of Practice |
| DBS outcome record (date, level, result, certificate number) | Duration of employment + 6 months | Legitimate interest / employment obligation |
| DBS Update Service check log | Duration of employment + 6 months | Consent |
| Biometric data (selfie) | Not retained by Opus and deleted by the IDSP after verification | Not applicable |
| AI interaction logs | 2 years | Audit, service improvement |
| AI tool execution audit logs | 6 years | Employment law, governance compliance, ICO accountability |
| AI approval records | 6 years | Governance compliance, employment law audit obligations |
| GPS location data | 2 years | Legitimate interest (attendance verification) |
| Marketing consent | Until withdrawn | Ongoing consent |
| Support tickets | 3 years after resolution | Service continuity |
After retention periods expire, data is securely deleted or anonymized.
8. Your Rights Under UK GDPR
Access (Art. 15)
Request a copy of all data we hold about you. Free of charge, response within 1 month.
Rectification (Art. 16)
Request correction of inaccurate data. Update in account settings or contact us.
Erasure (Art. 17)
Request deletion when data is no longer needed. Some data retained for legal obligations.
Restriction (Art. 18)
Limit processing while disputes are investigated.
Portability (Art. 20)
Receive your data in machine-readable format (JSON) for transfer.
Object (Art. 21)
Object to processing based on legitimate interests or direct marketing.
How to Exercise Your Rights
- • Online: Account Settings → Privacy → Data Rights
- • Email: compliance@opusplatforms.co.uk
- • Response time: Within 1 month (may extend to 3 months for complex requests)
- • Verification: We may request ID to prevent unauthorised access
Automated Decision-Making
We do not use fully automated decision-making that produces legal effects. Our RAG compliance system uses deterministic rules, not AI profiling. You always have the right to human review of any compliance decision.
A Data Protection Impact Assessment (DPIA) is maintained for our AI processing activities in accordance with UK GDPR Article 35 and ICO guidance on AI and data protection.
Your right to human review: You may request human review of any decision in which AI was involved by contacting compliance@opusplatforms.co.uk.
AI-Assisted Actions: Where AI proposes high-impact actions (e.g., payroll adjustments, compliance overrides, account suspensions), these are always routed to a human operator for explicit approval before execution. See §4.5 for our tiered governance framework.
Right to Withdraw Consent
Where we process your data based on consent (e.g., biometric verification, analytics cookies, talent pool participation), you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Withdraw via Account Settings or email compliance@opusplatforms.co.uk.
9. Security Measures
11. Children's Privacy
Our services are for individuals 18+ (UK minimum working age for most roles). We do not knowingly collect data from children. If discovered, it will be deleted immediately.
12. Policy Changes
We may update this policy to reflect legal or service changes. For material changes:
- We update the version number and date
- We notify you via email for significant changes
- We request renewed consent if legally required
Continued use after changes constitutes acceptance. Check back periodically for updates.
13. Contact & Complaints
Contact Opus
Email: compliance@opusplatforms.co.ukAddress: Unit 314b, 566 Cable Street, London, E1W 3HB
Complain to ICO
Information Commissioner's OfficeWycliffe House, Water Lane, Wilmslow, SK9 5AFPhone: 0303 123 1113ico.org.uk/make-a-complaint
We encourage you to contact us first so we can resolve your concern directly.
Version History
UK GDPR Compliant - This policy fulfills Articles 12, 13, and 14 transparency requirements.
Last reviewed: March 16, 2026 | Next review: September 2026