Employee & Contractor Privacy Notice

Introduction

Controller:
Numatic International Limited ‘Numatic’ is the Controller for any Personal Information gathered in the course of your engagement.

Data Protection Officer:
Paul Griffiths, DPO Centre. All requests must be sent to [email protected]. The request will be triaged by Numatic International and then referred to Paul Griffiths, as relevant.

Numatic is committed to protecting the privacy and security of the personal information that you share with us, or we generate as a result of our relationship.

This privacy notice:

• describes how we collect and use your personal information during and after your working relationship with us.
• Applies to all current and former employees, workers and contractors whose data we hold as a result of the working relationship that we have.
• Does not form part of any contract of employment or other contract to provide services.We may update this notice at any time and if we do so, we will provide you with an updated copy as soon as reasonably practical.

It is important that you read and understand this notice so that you are aware of how and why we are using your personal information. In some circumstances we may provide you with additional privacy information that describes a specific or new type of processing or when we need to collect additional information from you.

This notice explains how we meet the requirements of the UKs Data Protection Legislation. This means the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with this legislation.

The kind of information we hold about you

Personal data, or Personal Information, means any information about you (the data subject) from which you can be identified. It does not include data where information that could identify you have been removed (anonymous data) or general information that you generate in the course of your work with us (professional data).

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

• Personal contact details such as:
  • Addresses
  • Telephone numbers
  • Personal email addresses
• Information about you and your personal circumstances such as:
  • Name
  • Title
  • Date of birth
  • Gender and / or Gender identity
  • Marital Status, and Dependants’ information
  • Your nationality
• Emergency Contact information including Next of Kin
• Entitlement to work information.
• Copies of identification documents such as Passport or Driving License
• National Insurance Number or other tax related information
• Details of the bank to which we pay your salary.
• Records created as a result of your employment or engagement such as
  • Salary / Compensation / Remuneration (including historic information)
  • Benefits information such as pension and insurance information (including your entitlement to such benefit and any benefits that you have been in receipt of
  • Any form of leave you take (including annual, family friendly, sickness and compassionate)
  • Payroll records
  • Tax records
  • Work location and hours, including hours you have worked and when they were as collected by our clocking in system.
  • Job title and any changes to job title
  • Any training, disciplinary, grievance, performance, or sickness records including copies of information provided by you or sent to you.
  • The results of any tests that we conduct during or prior to your employment (including psychometric tests and notes)
  • Your start and leaving date.
  • After you have left – your reasons for leaving.
  • Continuous employment information
  • Information about your performance at work including appraisals, performance reviews, improvement plans and associated communications.
  • Any professional or academic qualifications that you have
  • Your skills and experience generated in your engagement with us.
  • Any information related to your terms and condition of engagement.
• Any information provided to us as part of your recruitment, such as your CV, references collected, work history, skills and qualifications.
• Any information that we generate as part of your application including interview notes, your application and any tests that we carry out.
• Information about your use of our IT and communications systems and / or processes including any information you enter into a Numatic controlled systems.
• Call recordings, including the digital recording of conversations and phone numbers.
• Electronic records such as CCTV footage and door entry logs

We may also collect, store and use the following “special categories” of more sensitive personal information which require a higher level of protection. They include:

• 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 including Occupational Health and Health Surveillance documentation.
• Information about criminal convictions and offences related to our screening processes or where you inform us of an offence.
• Where you leave us under a share plan or pension arrangement and the reason is ill health or disability, we keep records of this in support of the relevant entitlements.

How is your personal information collected

We collect personal information for you directly:

• Through the application and recruitment process, and
• In the course of your engagement with us

We may sometimes collect information from third parties including:

• Former employers
• Employment agencies
• Background check providers
• Credit reference agencies
• Pension providers

We will collect additional personal information in the course of your job-related activities throughout the period of you working for us.

We will collect and store the information about you that you provide to us in our HR systems.

How we will use personal information about you

We will only use your personal information where we can lawfully do so. Most commonly we will use your personal information to meet the below needs:

1. To perform the contract, we have entered into with you (either for employment or as a contractor) including making a decision about your initial engagement, determine the terms under which you will work, to pay you any compensation to which you are due and to manage any benefits entitlement (eg Healthcare and Pension)
2. To ensure your ongoing development with us including education, training and make decisions around your engagement.
3. To comply with our legal obligations such as in compliance with tax or health and safety obligations and to check your entitlement to work. We are also obliged to use special category information for Equal Opportunities monitoring.
4. To monitor your attendance at work based on your clocking in records. We also use such records to trigger sickness or absence procedures as well as to monitor against our Working Time obligations.
5. For our legitimate interests (or those of a third party) where such interests are not overridden by your rights, such as in monitoring our network to prevent and detect unauthorised or malicious activity.
6. To maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights.
7. To operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace (Including monitoring activity and use in our systems and using CCTV)
8. To operate and keep a record of your performance and related processes, to plan for career development, salary amendments, for succession planning and workforce management purposes.
9. To operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled.
10. To obtain occupational health advice, to ensure that we comply with duties in relation to individuals with disabilities, meet our obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled.
11. To operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that we comply with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled.
12. Internal and external phone calls are recorded to assist in the quality monitoring of staff performance, to investigate and resolve complaints, for the detection, investigation and prevention of crime, to take actions to protect staff from abusive callers.
13. To manage effective general HR and business administration
14. To provide references on request for current or former employees
15. To administer any employee benefits and to administer any share or pension plans that we choose to enrol individuals on to
16. To respond to and defend against legal claims.
17. To maintain and promote equality in the workplace.
18. To carry out criminal records, credit and address verification checks in line with our security screening policy to ensure that you are permitted to undertake the role in question.
19. To monitor your use of our information and communication systems to ensure compliance with our IT policies, and to use evidence of this in any Disciplinary processes.
20. To meet our legal obligations in the field of Employment Law

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access any information. This is to ensure that personal information is not disclosed to any person who has no right to receive it.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you. We may also be prevented from complying with our legal obligations (such as to ensure your health and safety or comply with Tax law).

If you have any concerns about the types of information we are collecting, or our use of that information please contact the Human Resources team who will be able to provide further information.

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.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.

Sensitive Data

We need to have further justification for collecting, storing and using special categories of data. We may process this kind 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 in connection with your employment or engagement
3. Where it is required by a specific law, such as for equal opportunities monitoring or in relation to our occupational pension scheme.
4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards

Our obligations as an employer

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

• We will use your 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.
• We will use information about your race or nationality or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
• If you leave us under a Share Plan or under any pension arrangement and the ground for leaving is ill health, we will use this information in determining your entitlements under any such plan

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with this policy or 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 need and the reason we need it. 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.

Information about criminal convictions

We 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 and provided, we do so in line with Data Protection law.

If your role requires any form of background screening you will be given additional information on the process.

You may also make us aware of any criminal history as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. In such cases we will use this information so we can make adjustments to your working environment to account for any restrictions.

Access to your data

Your information will be shared internally to ensure that we are meeting our obligations to you. This means certain information will be shared with the HR team, you line manager or supervisor, managers within your business unit. Your information may also be available to individuals with our IT teams. In all cases we only make available information that is required for each group to meet their needs.

We may share your data with third parties, including third-party service providers, in order to administer our relationship, comply with the law or where it is in our legitimate interest to do so.

We require third parties to respect the security of your data and to treat it in accordance with the law. We have contracts in place that include security and privacy requirements and a prohibition on using 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.

We may share personal information with the following categories of third parties:

• Service providers such as providers of payroll, administration, pension, benefits and HR services
• IT Service providers to enable to you access and use our IT equipment and so we can properly administrate these systems.
• Our legal advisors, any auditors, or other professional services providers
• The Police or any regulator at their request
• Other companies that may become part of our group or are in discussions with us around possible sale or restructure.
• Other Numatic entities who may manage shared services on our behalf such as business support, finance and HR services and as part of our regular business reporting, maintenance and data hosting or as part of any current projects or initiatives.

Transferring information outside the EEA

We will only transfer your personal information outside of the EEA when it is required in order for us to properly run our business.

Where we do need to make sure a transfer, we will ensure that either:

• The country has an adequacy decision in place, or
• The Standard Contractual Clauses are in place to cover the transfer.
  
  

As at the date of this notice Numatic does not transfer Employee information outside of the EEA.

Automated decision making

We do not make any legally significant decisions about you using automated means, we will notify you in if this position changes.

Data security

We have put in place appropriate security measures to protect the personal information you have entrusted to us, including putting in place systems and processes to prevent your personal information from being accidently lost, altered, disclosed, or otherwise used or accessed in an unauthorised way.

We limit access to all personal information to those individuals or third parties who have a business need to access that information this includes access to any information stored in our HR System.

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

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Details of specific retention periods for your information During and After your engagement can be found in HRP021 Retention of HR Documents Policy.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights

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 employment or engagement with us.

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

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
Request the transfer of your personal information to another party.
Right to withdraw consent; In the limited circumstances where we are processing your data on the basis of consent you have provided us, and we have no other legal justification or obligation to continue the processing, you have the right to withdraw your consent for that specific processing at any time.

If you would like to exercise any of these rights or would like to confirm the accuracy of your information, please contact the HR Team on [email protected]

Please note that you can update your personal information through the Numatic HR System at any time.

Complaints & queries

If you have any questions about this privacy notice or how we handle your personal information, please contact the HR Team in the first instance ([email protected]). They will escalate this to the Data Protection Lead as required.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. You can find the ICO’s contact details at https://ico.org.uk/global/contact-us/. However, we ask that you first contact the HR team so we can seek to resolve the issue.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.

In some circumstances we may provide you with supplementary information at the point that we need to collect new information or use your existing information in a new way.