Hooray is aware of its obligations under the General Data Protection Regulation (GDPR) and domestic data protection legislation, and is committed to processing your data securely and transparently. This privacy notice sets out, in line with current data protection obligations, the types of data that we collect and hold on you as an applicant or employee of the Business. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This notice applies to applicants, current and former employees and workers.
Data controller details
The Business is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:
Ian Moriarty, Operations Director
Data protection principles
In relation to your personal data, we will:
- process it fairly, lawfully and in a clear, transparent way
- collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
- only use it in the way that we have told you about
- ensure it is correct and up to date
- keep your data for only as long as we need it
- process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
Types of data we process
We hold many types of data about you, including:
- your personal details including your name, address, date of birth, email address, phone numbers
- your photograph
- information included on your CV including references, education history and employment history
- documentation relating to your right to work in the UK
- driving licence
- dependants, next of kin and their contact numbers
- medical or health information including whether or not you have a disability
- bank details
- tax codes
- National Insurance number
- current and previous job titles, job descriptions, pay grades, pension entitlement, hours of work and other terms and conditions relating to your employment/ engagement with us
- letters of concern, formal warnings and other documentation with regard to any disciplinary proceedings or, in the case of workers, confirmation of other discussions about your conduct
- internal performance information including measurements against targets, formal warnings and related documentation with regard to capability procedures, appraisal forms or, in the case of workers, confirmation of other discussions about your performance
- leave records including annual leave, family leave, sickness absence etc
- DBS check
- Training details
- CCTV footage
How we collect your data
We collect data about you in a variety of ways and this will usually start when we undertake a recruitment exercise where we will collect the data from you directly. This includes the information you would normally include in a CV or a recruitment cover letter, or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment/ engagement, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.
In some cases, we will collect data about you from third parties, such as former employers when gathering references or DBS agencies.
Personal data is kept within the Company’s HR and IT systems.
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Why we process your data
The law on data protection allows us to process your data for certain reasons only:
- in order to perform the employment contract that we are party to
- in order to carry out legally required duties
- in order for us to carry out our legitimate interests
- to protect your interests and
- where something is done in the public interest
- where we have obtained your consent.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. For example, we need to collect your personal data in order to:
- carry out the contract that we have entered into with you and
- ensure you are paid.
We also need to collect your data to ensure we are complying with legal requirements such as:
- ensuring tax and National Insurance is paid
- carrying out checks in relation to your right to work in the UK and
- making reasonable adjustments for disabled individuals.
We also collect data so that we can carry out activities which are in the legitimate interests of the Business. We have set these out below:
- making decisions about who to offer initial employment/engagement to, and subsequent internal appointments, promotions etc
- making decisions about salary and other benefits
- providing contractual benefits to you
- maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained
- if you are an employee, effectively monitoring both your conduct and your performance and to undertake procedures with regard to both of these if the need arises
- if you are an employee, offering a method of recourse for you against decisions made about you via a grievance procedure
- assessing training needs
- implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments
- gaining expert medical opinion when making decisions about your fitness for work
- managing statutory leave and pay systems such as maternity leave and pay etc
- business planning and restructuring exercises
- dealing with legal claims made against us
- preventing fraud
- ensuring our administrative and IT systems are secure and robust against unauthorised access
If you are unsuccessful in obtaining employment, we will seek your consent to retaining your data in case other suitable job vacancies arise in the Business for which we think you may wish to apply or for client vacancies. You are free to withhold your consent to this and there will be no consequences for withholding consent.
Special categories of data
Special categories of data are data relating to your:
- sex life
- sexual orientation
- ethnic origin
- political opinion
- genetic and biometric data.
Whilst we do not actively collect special category data, should you provide us with any special category data we must process it in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already made the data public.
We will use your special category data:
- in our sickness absence management procedures
- to determine reasonable adjustments
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process and our duties in line with your contract with us if offered employment. If you do not provide us with the data needed to do this, we will be unable to perform those duties e.g. the recruitment process or ensuring you are paid correctly. We may also be prevented from confirming, or continuing with, your employment/engagement with us in relation to our legal obligations if you do not provide us with this information eg. confirming your right to work in the UK.
Sharing your data
Your data will be shared with colleagues within the Business where it is necessary for them to undertake their duties. This includes, for example, a line manager for their recruitment or management of you, the HR/Admin department for maintaining personnel records and the payroll department for administering payment under your contract, the IT department where you require access to our systems to undertake any assessments requiring IT equipment.
We share your data with third parties in order to obtain references as part of the recruitment process. Other parties may include:
- HM Revenue and Customs
- Outsourced payroll, IT and HR
- Banks and other financial institutions
- Our insurers
- Our pension provider
- Social event organisers, venues and websites
- Social media sites, including those associated with fundraising activities
- Business gift and hospitality providers
- Data processors
- Agents and representatives
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.
We do not share your data with bodies outside of the European Economic Area.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. Any sensitive information is encrypted and protected. Non-sensitive details e.g. your e-mail address etc maybe transmitted via the internet which can never be guaranteed to be 100% secure. As a result, while we strive to protect personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best efforts to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential.
Our computer systems have Office 365 back up enabled. We use Bitdeffender which protects us against malware including advanced threat control, On-access check and Anti exploit protection. In addition we have content control with antiphising and network attach defence. Any company laptops are protected with AES 256 encryption by Bitlocker.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with current data protection requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, and this will depend on whether or not you are successful in obtaining employment with us and if this is the case it will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will not retain any records and any personal data will be shredded or deleted.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for 6 years once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdraw your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful and you are offered employment/placement with the Business, your data will be kept for the duration of your employment plus 6 years
The timescales for retention of your personal data and related documentation are subject to various legal, regulatory or contractual requirements, which will reflect the purpose and lawful basis for processing the data.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. You can read more about this in our subject access request policy which is available from [insert details]
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact Ian Moriarty, Operations Director
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.