The Company is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with Data Protection Legislation.
It applies to all employees, workers and contractors.
We will comply with data protection law. This says that the personal information we hold about you must be:
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)
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
We will collect, store, and use the following categories of personal information about you:
(a) Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
(b) Date of birth.
(d) Marital status and dependants.
(e) Next of kin and emergency contact information.
(f) National Insurance number.
(g) Bank account details, payroll records and tax status information.
(h) Salary, annual leave, pension and benefits information.
(i) Start date and, if different, the date of your continuous employment.
(j) Leaving date and your reason for leaving.
(k) Location of employment or workplace.
(l) Copy of driving licence.
(m) Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
(n) Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
(o) Compensation history.
(p) Performance information.
(q) Disciplinary and grievance information.
(r) CCTV footage and other information obtained through electronic means such as swipe card records.
(s) Information about your use of our information and communications systems.
(u) Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.
We may also collect, store and use the following more sensitive types of personal information:
(a) Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
(b) Trade union membership.
(c) Information about your health, including any medical condition, health and sickness records, including:
(d) where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;
(e) details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
(f) where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
(g) Genetic information and biometric data.
(h) Information about criminal convictions and offences.
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
(a) Making a decision about your recruitment or appointment.
(b) Determining the terms on which you work for us.
(c) Checking you are legally entitled to work in the UK.
(d) Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).
(e) Providing your employment benefits to you.
(f) Inviting you to participate in any share plans operated by a group company.
(g) Granting awards under any share plans operated by a group company.
(h) Administering your participation in any share plans operated by a group company, including communicating with you about your participation and collecting any tax and NICs due on any share awards.
(i) Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.
(j) Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits.
(k) Administering the contract we have entered into with you.
(l) Business management and planning, including accounting and auditing.
(m) Conducting performance reviews, managing performance and determining performance requirements.
(n) Making decisions about salary reviews and compensation.
(o) Assessing qualifications for a particular job or task, including decisions about promotions.
(p) Gathering evidence for possible grievance or disciplinary hearings.
(q) Making decisions about your continued employment or engagement.
(r) Making arrangements for the termination of our working relationship.
(s) Education, training and development requirements.
(t) Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
(u) Ascertaining your fitness to work.
(v) Managing sickness absence.
(w) Complying with health and safety obligations.
(x) To prevent fraud.
(y) To monitor your use of our information and communication systems to ensure compliance with our IT policies.
(z) To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your 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 paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
"Special categories" of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
We may process special categories of personal information in the following circumstances:
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.
In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, 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 from us.
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
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.
We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data. We will share personal data relating to your participation in any share plans and pension arrangements operated by a group company with other entities in the group for the purposes of administering the share plans.
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:
(a) 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.
(b) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
(c) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
(d) Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
(e) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
(f) Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Tony Smith or the Legal Department in writing.
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
In the limited circumstances 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 contact the data privacy or compliance manager. 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, unless we have another legitimate basis for doing so in law.
The company board of directors, and any data privacy or compliance manager appointed from time to time, have the responsibility 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 data privacy or compliance manager. 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.
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 data privacy or compliance manager.