• 1. Who does this section apply to?
  • This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

  • 2. The kind of information we hold about you

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 "special categories" of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth
  • Gender
  • Marital status and dependants
  • Next of kin and emergency contact information
  • National Insurance number
  • Bank account details, payroll records and tax status information
  • Salary, annual leave, pension and benefits information
  • Start date
  • Location of employment or workplace
  • Copy of driving licence
  • Recruitment information (including copies of passport, right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Employment records (including job titles, work history, working hours, training records and professional memberships).
  • Compensation history.
  • Performance information.
  • Disciplinary and grievance information.
  • CCTV footage.
  • Information about your use of our information and communications systems.
  • Photographs.

We may also collect, store and use the following "special categories" of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Trade union membership.
  • Information about your health, including any medical condition, health and sickness records.
  • Genetic information and biometric data.
  • Information about criminal convictions and offences.


3. How is your personal information collected?

We typically collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We will collect additional personal information in the course of job-related activities throughout the period of you working for us.


4. How we will use the information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we have entered into with you.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not over-ride those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest.


5. Situations in which we will use your personal information

We need all the categories of information in the list above (see The kind of information we hold about you) 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 of our own or those of third parties, provided your interests and fundamental rights do not over-ride those interests. The situations in which we will process your personal information are listed below.

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Checking you are legally entitled to work in the UK.
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions.
  • Providing any employee benefits to you that we may choose to offer from time to time and at our sole discretion.
  • Liaising with your pension provider.
  • Administering the contract we have entered into with you.
  • Business management and planning, including accounting and auditing.
  • Conducting performance reviews, managing performance and determining performance requirements.
  • Making decisions about salary reviews and compensation.
  • Assessing qualifications for a particular job or task, including decisions about promotions.
  • Gathering evidence for possible grievance or disciplinary hearings.
  • Making decisions about your continued employment or engagement.
  • Making arrangements for the termination of our working relationship.
  • Education, training and development requirements.
  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
  • Ascertaining your fitness to work.
  • Managing sickness absence.
  • Complying with health and safety obligations.
  • To prevent fraud.
  • To monitor your use of our information and communication systems to ensure compliance with our IT policies.
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
  • Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.


6. If you fail to provide 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).


7. Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


8. How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations

3. Where it is needed in the public interest.

4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

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.


9. Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.


10. Do we need your consent?

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.


11. Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary 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.

We do not envisage that we will hold information about criminal convictions.


12. Why might you share my personal data with third parties?

We may 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.


13. Which third-party service providers process your information?

"Third parties" includes third-party service providers (including contractors and designated agents. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration.


14. How secure is my information with third-party service providers?

All our third-party service providers 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.


15. What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.


16. Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Eric Whitehead.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.


17. 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.


18. 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 Eric Whitehead.. 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.


Issue Date: 28th March 2018.

Version History 1.0