GDPR Policy Statement

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 This Policy explains how the company handles and uses information it collects about its staff. This Privacy Notice applies to all current and former employees, workers and contractors within the Company. 

We make every effort to comply with the General Data Protection Regulation and Data Protection Act 2018 and understand the importance of maintaining your confidentiality.

This notice is non-contractual and can be amended at any time.

What type of information does the Company hold?

• Personal data: this means any information about an individual from which that person can be identified. It does not include data where the individual’s identity has been removed (anonymous data).
• Special category data: this means data about an individual of a more sensitive nature and requires a higher level of protection. 
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On what basis does the Company process your information? 

The Company will only use your personal information when permitted by the law. Most commonly, the Company will use your personal information in the following circumstances:

• Where it needs to perform the contract it has entered into with you (*).
• Where it needs to comply with a legal obligation (**).
• Where it is necessary for the Company’s legitimate interests (or those of a      third party) and your interests and fundamental rights do not override those interests (***). The legitimate interests of the Company are to manage your ongoing employment relationship (or engagement) and it believes that this is not incompatible with your rights and freedoms. 

We have indicated by asterisks below the purpose or purposes for which the Company processes your personal information. Some of the grounds for processing will overlap and there may be several grounds which justify the Company’s use of your personal information. 

• The Company may process ‘special categories’ of sensitive information in the following circumstances: 

In limited circumstances, with your explicit written consent;

• Where it needs to carry out its legal obligations and in line with its Data Protection Policy and health and safety obligations;
• Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards; and
• Where it is necessary to comply with employment law.

What personal information about you is processed by the Company?

Upon commencement of employment/engagement your personal data will be processed. This includes, but is not limited to the following information:

• Name, title and gender (* and ** and ***)
• Address, contact details and emergency contact details (* and ** and ***)
• Age (** and ***)
• Date of Birth (** and ***)
• National insurance number (* and **) 
• Right to Work Paperwork (* and **)
• Nationality (** and ***)
• Bank Details (* and **)
• Marital Status / Civil Partnership (***)
• Recruitment information including application form / CV, proof of qualifications, references, interview notes, offer of employment (* and ** and ***)
• Working time records (* and ** and ***)
• Current and previous salary, benefits, other earnings (e.g. maternity pay, overtime) and statutory taxes (* and **)
• Photographs e.g. at a company-related event (***)
• Terms and conditions of employment including job titles and work history (*and ** and ***)
• Holiday records (* and **and ***)
• Training record, requests, Certificates and Licence Cards (* and ***)
• College enrolments / Training Bookings (***)
• Absence records (* and** and ***) 
• Health and Safety records (** and ***)
• Clock card records (* and ***)
• Performance information including disciplinary and grievance records (*and***)
• Site Security Clearance Applications (* and ***) 
• Company credit card statements (**and***)
• Drug and alcohol test results (**and***)
• Information about your use of the Company’s information and communication systems (***)
• CCTV footage and other information obtained through electronic means such as swipe card records and company-owned mobile telephone records (***)

The Company may also collect, store and use the following ‘special categories’ of more sensitive personal information:

• Information about your health, including any medical condition (physical or mental), health and sickness records, lifestyle choices, occupational health assessments and related work requirements; and
• Information as to your ethnic Company and religion.

This data above may be collected by various methods during the course of employment/engagement, such as electronically, verbally or in writing.

How will your personal data be used by the Company?

Your personal data will be used in various ways during your employment/engagement, which includes, but is not limited to:Ensuring that you have the right to work for the Company 

• Making a decision about your recruitment or appointment
• Determining the terms on which you work for the Company and making decisions about your continued employment
• Administering the contract that we entered into with you
• Record administration and management purposes
• Payroll processing and deducting tax and National Insurance Contributions
• Benefits administration
• Performance and salary reviews
• Site Induction / Security Clearance 
• Managing your sickness absences, providing you with any necessary support to return to work and taking decisions about your future fitness for work
• Managing your conduct
• Training and development requirements
• Complying with health and safety obligations, maintaining Health and Safety Records, including Risk Assessments, Method Statements, Permits to Work
• Accident Investigations and dealing with legal disputes involving you, or other employees, workers and contractors (where required)
• Dealing with concerns you raise about your employment and/or treatment
• Making arrangements for the termination of your employment
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;
• Monitoring your use of the Company’s information and communication systems to ensure compliance with the Company’s IT policy;
• Monitoring equality and diversity within the Company

The Company typically collects personal information about staff through the application and recruitment process, either directly from candidates or sometimes from an employment agency. 

The Company will use your ‘special categories’ of sensitive personal information in the following ways (this list is not exhaustive):

• 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, to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
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What happens if you fail to provide personal information?

Where the provision of your personal data is required for the Company to enter into an employment contract with you, or is a statutory requirement, (e.g. evidence of a right to work in the UK, details of salary/benefits, national insurance number, health and safety of workers), refusal to provide this personal information will prevent the Company from being able to employ you, ensure your health and safety and/or administer your pay and benefits.

Will you be subject to Automated Decision Making?

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless the Company has a lawful basis for doing so and it has notified you.

Who will your personal information be disclosed to

Your personal information will be accessed by authorised staff who need to have access to that information (i.e. the HR department, your line manager, payroll and any other relevant manager/internal department. 

The Company may also have to share your data with third parties, including third-party service providers and other entities in the Company 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. The following activities are carried out by third-party service providers: 

• payroll;
• benefits provision and administration including pension;
• IT services including the logging of health and safety incidents;
• training;
• occupational health and medical assessments;
• archiving activities;
• auditing; and
• employment agencies
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The Company requires third parties to respect the security of your data, to take appropriate security measures and to treat it in accordance with the law. The Company only permits third parties to process your personal data for specified purposes and in accordance with its instructions.

The Company may share your personal information with a regulator or to otherwise comply with the law. 

No personal information will be transferred to a third party located outside of the European Economic Area (EEA), unless we are certain that an adequate level of protection exists in relation to the processing of that information.

How long is my personal information retained

The Company does not keep personal data any longer than is necessary and commits to disposing it securely in line with the Company Retention Period’s detailed within the Data Protection Policy available from the HR Department.

News Articles and Award Submissions 

From time to time, the Company may request to use your photograph, name and other information within a news article, business briefing or award submission. Where this arises, a representative of the Company will approach you for your consent. 

You will always be given the opportunity to read and agree the article / award application written on your behalf before it’s publicised. Should you disagree with the content you can request it is amended. 

In the event you do not give consent for the information to be published, the Company commits to deleting any copies of the drafted articles / applications.

What are your rights relating to your personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). 
• Request correction of the personal information that the Company holds about you. 
• Request the erasure of your personal information. 
• Request the restriction of and objection to processing of your personal information. 
• Request the transfer of your personal information to a third party.

Please see the Company’s Data Protection Policy for further information on your rights and specific information that the Company may require from you. 

In addition, in the limited circumstances where you may have provided your consent to the processing of your personal information, you have the right to withdraw your consent at any time. To withdraw your consent, please contact info@delstron.co.uk in writing. 

Some of these rights are not automatic, and the Company reserves the right to discuss with you why it might not comply with a request. If you want to exercise any of the above rights, please contact e-mail info@delstron.co.uk 

Contact Details 

You retain the right to lodge a complaint about the Company’s management of your personal data with the Information Commissioner’s Office at https://ico.org.uk/concerns/.

Should you have any questions regarding the content of this Privacy Notice and / or how the Company process your personal data, please contact the HR Department by e-mailing info@delstron.co.uk