Why we use your personal information
It is necessary for us to process personal data of both job applicants and workers for the following reasons:
- We will need the information in order to identify the individual for the purposes of recruitment;
- We will need to maintain that information for the general purposes of the ongoing employment relationship including performing the employment contract and maintaining the health and safety of individuals on our premises.
How we obtain your personal information and the types of personal information we may obtain
Your personal information is directly given by you or from a Recruitment Agenda.
The type of personal information in relation to you we process may include - e. g. (this is not an exhaustive list): -
- General Personal details (Name, Address & contact Info, DOB, etc);
- Education, Qualifications, Training Records;
- Employment History;
- Pre-employment Checks (Ability to Work, Criminal Records Checks (CRC))
- Employment and/or Personal References;
- Equal Opportunity Data (Ethnic Origin, Gender, Religion, Sexual Orientation etc);
- Pre-existing medical conditions at the time of employment;
- Occupational health records;
- Benefit Providers (and associated information);
- Unique identifiers and reference numbers that we or others have allocated to you (e.g. Employee ID/Payroll No, NI and other numbers);
- Photographs of you;
- Employment Performance Records (e.g. appraisals, disciplinary notes etc);
- Holiday and sickness records;
- Your financial information, including, where relevant, details of your salary, bonuses, bank details, tax records etc.
- Your Next of Kin and family (e.g. their relationship to you, address, contact details etc).
Our legal basis for using your personal information
In line with our Record of Processing Activity (ROPA) our legal basis for processing personal data of applicants and workers is that:
- Processing the personal data is necessary for the purpose of carrying out the employment contract or to take steps to enter into an employment contract;
- Processing is necessary to comply with a legal obligation (for example we are obliged under employment law to include in a written statement of employment terms the identity of the parties to the employment contract);
- Processing the data is necessary to protect the vital interests of an individual (for example we are legally responsible for the health and safety of staff and job applicants (when they are on our premises) and so it is necessary to process data relating to those individuals for that reason); and/or
- Processing the data is necessary for the purposes of our “legitimate interests” as the data controller (except where such interests are overridden by the interests, rights or freedoms of the individual).
Our “legitimate interests” for these purposes are:
- The need to process data on applicants and staff for the purposes of assessing suitability for employment and then carrying out the employment contract;
- The need to gather data for the purposes safeguarding the health and safety of job applicants and employees;
- The need to transfer employee data intra-group for administrative purposes; and
- The need to process employee data for the purposes of ensuring network and information security.
We may from time to time need to process Special Categories of Data, for example medical records or other information relating to the health and wellbeing of an individual.
In that case we will either obtain the explicit consent of the individual to the processing of such data or we may consider the processing of that data as being necessary for carrying out our obligations as an employer. That will be assessed on a case by case basis.
If you do not provide at least that data that is necessary for us to assess suitability for employment and then to conduct the employment relationship then it will not practically be possible for us to employ you.
Who we may share your personal information with
Your personal data may be received by the following categories of people:
- Our HR department;
- In the case of job applicants, the interviewer and prospective manager;
- Any individual authorised by us to maintain personnel files;
- Our professional advisers;
- Our Technology Providers;
- Training Providers and Awarding/Examining Bodies – for the provision of information in relation to the qualifications of our workforce;
- Employee Membership / Benefit providers; and
- Appropriate external regulators and authorities (such as HMRC and HSE)
How long we keep hold of your data
We retain the personal information processed by us, only for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Our Records Retention Policy sets out how long records should be retained.
Examples are: - Income tax and NI returns, income tax records, wage and salary records and correspondence with HMRC: We are obliged to keep these records for 6 years after the end of the financial year to which they relate.
Automated Decision Making & Profiling
We do not make any decisions in relation to your personal information, solely by automated means without any human involvement (e.g. we do not conduct automated decision making).
Neither do we conduct any automated processing of personal information to evaluate certain things about you (e.g. we do not conduct profiling).