Privacy Policy

GDPR data protection privacy notice (employment) 

EWS Limited

Data protection privacy notice (employment) 

This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during your employment and after it ends. We are required to notify you of this information under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you. 

Who collects the information 

TEWS Limited (‘Company’) is a ‘data controller’ and gathers and uses certain information about you.   

Data protection principles 

We will comply with the data protection principles when gathering and using personal information, as set out in our data protection policy. 

About the information we collect and hold 

What information

We may collect the following information during your employment: 

• Your name, contact details (i.e. address, home and mobile phone numbers, email address) and emergency contacts (i.e. name, relationship and home and mobile phone numbers);
• Information collected during the recruitment process that we retain during your employment;
• Employment contract information;
• Details of salary and benefits, bank/building society, National Insurance and tax information, your age;
• Details of your spouse/partner and any dependants;
• Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
• A copy of your driving licence;
• Details of your share incentive arrangements, and all information included in these and necessary to implement and administer them;
• Details of your pension arrangements, and all information included in these and necessary to implement and administer them;
• Information in your sickness and absence records (including sensitive personal information regarding your physical and/or mental health);
• Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
• Criminal records information, including the results of Disclosure and Barring Service (DBS) checks;
• Your trade union membership;
• Information on grievances raised by or involving you;
• Information on conduct and/or other disciplinary issues involving you;
• Details of your appraisals and performance reviews;
• Details of your performance management/improvement plans (if any);
• Details of your time and attendance records;
• Information regarding your work output;
• Information in applications you make for other positions within our organisation;
• Information about your use of our IT, communication and other systems, and other monitoring information;
• Your image, in photographic and video form;
• Details of your use of business-related social media, such as LinkedIn;
• Your use of public social media (only in very limited circumstances, to check specific risks for specific functions within our organisation; you will be notified separately if this is to occur);
• Details in references about you that we give to others.

Certain of the categories above may not apply to you if you are an agency worker, independent contractor, freelancer, volunteer or intern. 

How we collect the information 

We may collect this information from you, your personnel records, the Home Office, share scheme administrators, pension administrators, your doctors, from medical and occupational health professionals we engage and from our insurance benefit administrators, the DBS, your trade union, other employees, consultants and other professionals we may engage, e.g. to advise us generally and/or in relation to any grievance, conduct appraisal or performance review procedure, systems used e.g. door entry systems, swipe card systems, time management system, time clock records, application logs, details of relevant systems, such as screen capture, application logs, webcams, automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, remote access systems, email and instant messaging systems, intranet and Internet facilities, telephones, voicemail, mobile phone records, data loss prevention tools, next-generation firewalls, unified threat management systems, transport layer security, eDiscovery technology, mobile device management systems, relevant websites and applications. 

Why we collect the information and how we use it 

We will typically collect and use this information for the following purposes (other purposes that may also apply are explained in our data protection policy: 

• for the performance of a contract with you, or to take steps to enter into a contract;
• for compliance with a legal obligation (e.g. our obligations to you as your employer under employment protection and health safety legislation, and under statutory codes of practice, such as those issued by Acas); 
• for the purposes of our legitimate interests or those of a third party (such as a benefits provider), but only if these are not overridden by your interests, rights or freedoms.

Further information on the monitoring we undertake in the workplace and how we do this is available in our data protection policy and in our Staff handbook that deals with monitoring undertaken by the employer, available from the HR department. 

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it. 

How we may share the information 

We may also need to share some of the above categories of personal information with other parties, such as external contractors and our professional advisers and with potential purchasers of some or all of our business or on a re-structuring.  Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators or as required to comply with the law. 

Where information may be held 

Information may be held at our offices and third-party agencies, service providers, representatives and agents as described above. 

Sensitive personal information and criminal records information 

Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our data protection which is available from the HR department. 

How long we keep your information
 
We keep your information during and after your employment for no longer than is necessary for the purposes for which the personal information is processed.  

Your rights to correct and access your information and to ask for it to be erased 

Please contact team@ews.co.uk if, (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice.   

You also have the right to ask for some but not all of the information we hold and process to be erased (the 'right to be forgotten') in certain circumstances and can contact Trinity by email (as per the details above) should you have any queries in this regard. 

Keeping your personal information secure 

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way.  We limit access to your personal information to those who have a genuine business need to know it.  Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 

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

How to complain 

We hope that our Legal Department can resolve any query or concern you raise about our use of your information.  If not, contact the Information Commissioner at ico.org.uk/concerns or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint. 

Dated: 25 May 2018