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Data controller
Difrent, HyHubs, Hoults Yard Estate, Walker Road, Newcastle upon Tyne, NE6 1AB
Data protection officer
Graeme Dykes, graeme.dykes@summit-management.co.uk
The organisation collects and processes personal data relating to its employees to manage the employment relationship. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
The organisation collects and processes a range of information about you. This includes:
The organisation collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment (such as benefit nomination forms); from correspondence with you; or through interviews, meetings or other assessments.
In some cases, the organisation collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies, information obtained from social media monitoring and information from criminal records checks permitted by law.
The organisation needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer benefit, pension and insurance entitlements.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws, to enable employees to take periods of leave to which they are entitled, and to consult with employee representatives if redundancies are proposed or a business transfer is to take place. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question. It may also be necessary to process criminal records data in the context of disciplinary or grievance proceedings, for example to investigate and take appropriate action if you are suspected of committing an offence (whether at or outside work).
In other cases, the organisation has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the organisation to:
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
Some special categories of personal data, such as information about health or medical conditions, or racial or ethnic origin, is processed to carry out employment law obligations (such as those in relation to employees with disabilities, for health and safety purposes and to ensure that employees have the right to work in the UK).
Where the organisation processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that the organisation uses for these purposes is anonymised or is collected with the express consent of employees, which can be withdrawn at any time by contacting the People Manager. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.
As noted above, the organisation may process criminal records data to assess your suitability for employment both when you are recruited (through appropriate criminal records checks) and in the course of your employment.
Your information will be shared internally, including with members of the HR and recruitment team (including payroll), your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.
Your data may also be shared with employee representatives in the context of collective consultation on a redundancy or business sale. This would be limited to the information needed for the purposes of consultation, such as your name, contact details, role and length of service.
The organisation shares your data with third parties to obtain pre-employment references from other employers, obtain employment background checks from third-party providers, obtain necessary criminal records checks from the Disclosure and Barring Service, or report suspected offences to the appropriate authorities. The organisation may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.
The organisation also shares your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits and the provision of occupational health services.
The organisation will not transfer your data to countries outside the UK.
The organisation takes the security of your data seriously. The organisation has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
Where the organisation engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
The organisation will hold your personal data for the duration of your employment. The periods for which your data is held after the end of employment are 6 years.
As a data subject, you have a number of rights. You can:
If you would like to exercise any of these rights, please contact the People Manager.
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.
You have some obligations under your employment contract to provide the organisation with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide the organisation with data to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.
Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable the organisation to enter a contract of employment with you. If you do not provide other information, this will hinder the organisation’s ability to administer the rights and obligations arising as a result of the employment relationship efficiently.
Employment decisions are not based solely on automated decision-making.
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