Privacy Policy for Employees & Role Applicants

Privacy Notice for Employees & Role Applicants

For the purposes of this Privacy Notice, personal information is any information about an identifiable individual. Personal information does not include anonymous or non-personal information.

We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were employed by us, including the personal information contained in:

• CVs and applications;

• references and interview notes;

• DBS and vetting information;

• Education and training information;

• Right to work information;

• Photographs, testimonials, video and audio recordings including CCTV imagery;

• letters of offer and acceptance of employment and other employment records;

• policy acknowledgement sign-off sheets;

• payroll information; including but not limited to national insurance number, banking and deposit information and national insurance number;

• wage and benefit information including annual leave information;

• forms relating to the application for welfare benefits;

• Health questionnaires and risk assessments including details of any medical condition or medication you are taking; 

• beneficiary and emergency contact information;

• Disciplinary and grievance records;

• Your driving licence and insurance documentation; and

• Equal opportunities monitoring forms 

In addition to the examples listed above, the personal information we collect includes information such as your name, home address, telephone, personal email address, date of birth, employee identification number, ethnicity, marital status, nationality, next of kin/emergency contact information, salary, biometric data provided and any other information necessary for business purposes, which is voluntarily disclosed in the course of an employee's application for and employment with us.

The above lists are non-exhaustive and applies across the Company. A complete list of information held on you is available from the Data Protection Officer.

As a general rule, we collect personal information directly from you. We may however also use recruitment consultants and recruitment websites to source potential applicants. In most circumstances where the personal information that we collect about you is held by a third party, we will only process it in accordance with our legitimate interests, where necessary for the performance of our contracts or where obligated by law. 

From time to time, we may use the services of third parties, such as recruitment agents and may also receive personal information collected by those third parties in the course of the performance of their services for us. In that case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

The personal information collected is used and disclosed for our business purposes, including establishing, managing or terminating the employment relationship and complying with our obligations to you. It is necessary for the performance of our contract with you and/or performing our obligations under a contract as well as to meet our legal obligations and legitimate interests. In respect of special category data, which includes health data, it is necessary for your employment, social security and social protection, reasons of substantial public interest and/or for reasons of public interest in the area of public health, such as protecting against serious threats to health. Such uses include:

• determining eligibility and suitability for initial employment, including profiling from any previous job application to us, right to work checks and the verification of references and qualifications;

• administering pay and benefits including holiday pay;

• processing employee work-related claims (e.g. insurance claims, etc.)

• establishing training and/or development requirements;

• conducting performance reviews and determining performance requirements;

• assessing qualifications and suitability for a particular job, task, bonus or promotion;

• gathering evidence further to the disciplinary, grievance or whistleblowing procedure;

• establishing a contact point in the event of an emergency (such as next of kin);

• considering, assessing and preventing inequality or health & safety incidents or risks; 

• for pandemic monitoring and infection control purposes;

• to obtain extra or emergency funding including for wages or personal protective equipment during local, regional or national emergencies and/or pandemics

• complying with all regulatory and legislative requirements;

• compiling contact lists for internal purposes only;

• analysing workforce trends e.g. impact of Covid-19 or other pandemics or regulatory or legislative changes;

• ensuring your security and the security of company held information and data; and

• such other purposes as are reasonably required by us for the performance of your contract; to protect vital interests; for the performance of a task in the public interest; to comply with our legal obligations; in accordance with our legitimate business interests or for the purpose of assessing your working capacity.

How Do We Use Your Personal Information?

We may use your personal information for the purposes described in this Policy, or for any additional purposes that we advise you of and where your consent is required by law we have obtained your consent in respect of the use or disclosure of your personal information.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

We may share your personal information with our employees, clients, contractors, advisers or consultants and other parties who require such information to assist us with establishing, managing, funding or terminating our employment relationship with you, including: professional advisers, parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you.  

Also, your personal information may be disclosed:

• as necessary for the performance of our contract with you

• as permitted or required by applicable law or regulatory requirements. In such a case, we will try to not disclose more personal information than is required under the circumstances;

• to comply with valid legal processes such as warrants or court orders;

• as part of our regular reporting activities to our clients or other members of the Company, i.e. if necessary for the performance of your contract, to comply with a legal obligation or as part of our legitimate business interests;

• to protect the rights and property of the company or others;

• during emergency situations or where necessary to protect the vital interests or safety of a person or Company of persons;

• to assess your working capacity;

• if in the substantial public interest;

• where the personal information is publicly available; or

• with your consent.

We endeavour to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. This includes the use of firewalls and encryption as well as other information security requirements, systems and procedures. These safeguards are designed to protect your personal information from loss and unauthorised access, copying, use, modification or disclosure.

We also use data sharing agreements, data processing agreements and the standard contractual clauses to protect your data where it is being shared, processed and/or transferred to a third country.