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Privacy Notice – Employees, Freelancers & Job Applicants

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1.       Introduction

1.1     At Strategic North we are committed to maintaining the trust and confidence of anyone who discloses their details to us, including employees, freelancers, consultants and those who are interested in working for us. In particular, we want you to know that Strategic North is not in the business of passing on your personal information to other companies and businesses for marketing purposes. Just in case you want to find out more, in this Privacy Notice, we’ve provided lots of detailed information on when and why we collect your personal information, how we use it, the limited conditions under which we may disclose it to others, how we keep it secure and how you can get in touch to delete or amend any of your personal information.

1.2     If you are applying for a job with us, the information which is specific to you can be found at the end of the document (ref point 8), so you can skip over much of this document if you prefer to do so. For freelancers and consultants, we will follow what we say we will do for staff, for personal data about you, albeit we may not need to process as much information or provide as much to third parties, due to the nature of your engagement with us and the way you are recompensed.

1.3     Strategic North is the data controller, which means we are responsible for deciding how we use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

1.4     We also have a data protection policy which outlines in more detail our approach to data and what you as a member of staff are obliged to do. If you are looking for that information that can be found in: G Drive – Internal Admin all staff – Company Policies & Sops or at strategicnorth.com.

 

2.       Type of data we collect

2.1     We operate a strict data minimisation approach at Strategic North so we only collect and process data that is necessary for us to effectively run and manage the Business including occasionally sharing information about who we are and what we do.

2.2     We also only keep it for as long as it is needed to do this. Once it isn’t essential we remove it from our systems.

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

(a) Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

(b) Date of birth.

(c) Marital status and dependants.

(d) Next of kin and emergency contact information.

(e) National Insurance number.

(f) Bank account details, payroll records and tax status information.

(g) Salary, annual leave, pension and benefits information.

(h) Start date.

(i) Copy of passport.

(j) Copy of Driving Licence and Insurance certificate.

(k) Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).

(l) Employment records (including job titles, work history, working hours, training records and professional memberships).

(m) Compensation history.

(n) Performance information.

(o) Disciplinary and grievance information.

(p) Information about your use of our information and communications systems.

2.4     We may also collect, store and use the following “special categories” of more sensitive personal information:

(a) Information about your nationality.

(b) Information about your health, including any medical condition, health and sickness records.

(c) Information about criminal convictions and offences.

2.5     We typically collect personal information about employees, freelancers, and job applicants through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

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

 

3.           What we do with data

3.1     We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

(a) Where we need to perform the contract we have entered into with you.

(b) Where we need to comply with a legal obligation.

(c) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

3.2     We may also use your personal information in the following situations, which are likely to be rare:

(a) Where we need to protect your interests (or someone else’s interests).

(b) Where it is needed in the public interest.

3.3     We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

(a) Making a decision about your recruitment or appointment.

(b) Determining the terms on which you work for us.

(c) Checking you are legally entitled to work in the UK.

(d) Paying you and, if you are an employee, deducting tax and National Insurance contributions.

(e) Providing the following benefits to you: Company Mobile, Health Insurance, Corporate Credit Card.

(f) Liaising with your pension provider.

(g) Administering the contract we have entered into with you.

(h) Business management and planning, including accounting and auditing.

(i) Conducting performance reviews, managing performance and determining performance requirements.

(j) Making decisions about salary reviews and compensation.

(k) Assessing qualifications for a particular job or task, including decisions about promotions.

(l) Gathering evidence for possible grievance or disciplinary hearings.

(m) Making decisions about your continued employment or engagement.

(n) Making arrangements for the termination of our working relationship.

(o) Education, training and development requirements.

(p) Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.

(q) Ascertaining your fitness to work.

(r) Managing sickness absence.

(s) Complying with health and safety obligations.

(t) To prevent fraud.

(u) To monitor your use of our information and communication systems to ensure compliance with our IT policies.

(v) To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

(w) To conduct data analytics studies to review and better understand employee retention and attrition rates.

(x) Equal opportunities monitoring.

3.4     Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

3.5     If you fail to provide personal information. If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

3.6     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.

3.7     Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.8     Special categories of personal information. “Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

3.8.1     In limited circumstances, with your explicit written consent.

3.8.2     Where we need to carry out our legal obligations and in line with our data protection policy.

3.8.3     Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy.

3.8.4     Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

3.9     Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.

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

(a) 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.

(b) 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.

(c) We will use information about your nationality to obtain a corporate credit card used for Business expenses.

3.11     We do not need your consent if we use special categories of your personal information in accordance with our written policy 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 would like and the reason we need it, so that you can carefully consider whether you wish to consent. 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.

3.12     Criminal convictions. We envisage that we may hold information about criminal convictions. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions 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.

3.13     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 we have a lawful basis for doing so and we have notified you.

3.14       We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

 

4.    With whom might we share your data

4.1     We may have to share your data with third parties, including third-party service providers and other entities in the group.

4.2     We require third parties to respect the security of your data and to treat it in accordance with the law.

4.3     We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

4.4     Why might you share my personal information with third parties? We may share your personal information with third parties 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.

4.5     Which third-party service providers process my personal information? “Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers who currently are:

4.5.1     Payroll – TLP Consulting Ltd.

4.5.2     Pension administration – Royal London & Craven and Slater.

4.5.3     Benefits provision and administration – Westfield, Vitality Health & Personal Health Care Management, Mobile Phones – Vodafone & PMCG Technology Group Ltd.

4.5.4     IT services – Hale IT.

4.5.5     Banking – Lloyds TSB and Barclaycard.

4.6     How secure is my information with third-party service providers and other entities in our group? All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use 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.

4.7     When might you share my personal information with other third parties? We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

4.8     Transferring information outside the EU. The data that we collect from you is stored with a Cloud based provider that may be in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with the applicable laws.

4.9     For transfer outside the EEA, Strategic North Ltd will use Standard Contractual Clauses and Shields as safeguards for countries without adequacy decisions from the European Commission.

 

5.          How do we protect your data.

5.1     We have put in place measures to protect the security of your information. Details of these measures are available in the data protection policy.

5.2     Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

5.3     We only ever use IT platforms that are GDPR compliant.

5.4     We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Head of HR and Head of Finance and Business Operations.

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

 

6.       How long do we keep your data.

6.1     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 retention periods for different aspects of your personal information are confirmed below. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6.2     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. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with the time periods below.

6.3     We will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require. This includes requiring third parties to delete such data where applicable.

6.4 .   The documentation retention periods which we will apply in relation to certain data are as follows, but we will from time to time record separately the periods for which we will retain other data not covered by the headings below (documentation will be retained for a slightly longer period to ensure that the relevant period has expired and destruction or erasure of records may take place periodically meaning that records will be retained slightly longer than detailed):

(a) Personnel files and records including information relating to salaries and benefits and the terms upon which employees are engaged and steps taken in relation to them during employment, training records and disciplinary records – 7 years from the end of employment;

(b) Some information will be retained in order to ensure that references and other confirmation of dates and details of employment can be provided – indefinitely;

(c) Records regarding pensions and pension contributions and retirement benefits – 7 years from the end of employment, or such longer period as is appropriate in relation to the scheme and the benefits to which it relates (up to six years after the benefit ceases to be payable);

(d) Medical records, depends upon the nature of the records. Most will be held for 7 years from the end of employment, but some such as those relating to lead, asbestos and other hazardous substances will be held for the longer periods required (up to 40 years in some cases);

(e) Tax and NI returns, records and correspondence with HMRC – 7 years from the end of the financial/tax year to which they relate;

(f) Details of wages and salaries (including overtime, bonuses, expenses) – 7 years from the end of the financial year to which they relate;

(g) Company photos of you – 2 years from the end of employment.

(h) Copy of passport – 3 years from the end of employment.

(i) Copy of Driving license and insurance certificate – 3 years from end of employment.

6.5     For recruitment information see the section on information for job applicants below (ref point 7).

  

7.   Your privacy rights and who to contact about them

7.1     Your duty to inform us of changes. 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 working relationship with us.

7.2     Your rights in connection with personal information. Under certain circumstances, by law you have the right to:

(a) 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 and to check that we are lawfully processing it.

(b) 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.

(c) 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 (see below).

(d) 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 particular 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.

(e) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

(f) Request the transfer of your personal information to another party.

7.3     If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Head of HR & Head of Finance and Business Operations in writing.

7.4     No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

7.5     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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

7.6     Right to withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Head of HR & Head of Finance and Business Operations. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

8.       Information specific to job applicants

8.1     The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.

8.2     The organisation will not usually use your data for any purpose other than the recruitment exercise for the role for which you have applied. However where you agree to us doing so or where you ask us to do so, where your initial application is unsuccessful the organisation may keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

8.3     If your application for employment is unsuccessful, the organisation will hold your data on file for six months after the end of the relevant recruitment process. However, where you have agreed/requested that we keep it for a longer period then we may keep it for up to two years after the recruitment process has concluded. At the end of that period or once you withdraw your consent, your data will be deleted or destroyed (although we may undertake such destruction periodically so it may be held for slightly longer pending the next destruction process).

8.4    If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be those outlined for employees.

 

9.       Changes to our privacy notice

9.1    We monitor our privacy notice regularly and may update it at any time. If we do we will send you a notification email to update you on how we are processing and protecting your data.

 

This notice was last updated on May 17th 2018

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