JHP RECRUITMENT LTD PRIVACY NOTICE
JHP Recruitment Ltd is committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.
This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights about data that we hold about you. It applies to current and former employees, workers, volunteers, interns and contractors and does not form part of any contract of employment or other contract to provide services. For more information please contact Data Protection lead who will provide you with our Data Protection Policy.
THE INFORMATION WE COLLECT FROM YOU
Personal individual information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth.
- Marital status and dependants.
- Next of kin and emergency contact information.
- National Insurance number.
- Bank account details, payroll records, travel logs and expenses and tax status information.
- Salary, annual leave, pension and benefits information.
- Start date.
- Location of employment or workplace.
- Access to your DVLA portal.
- Recruitment information (including copies of right to work documentation, passport, references and other information included in a CV or cover letter or as part of the application process).
- Employment records (including job titles, work history, working hours, training records and professional memberships).
- Compensation history.
- Performance information.
- Disciplinary and grievance information.
- CCTV footage and other information obtained through electronic means such as swipecard records.
- Information about your use of our information and communications systems.
We may also collect, store and use “special categories” of more sensitive personal data which require a higher level of protection:
- Information about your health, including any medical condition, health and sickness records (including Occupational Health records).
- Absence notes
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Trade union membership.
- Genetic information and biometric data.
- Information about criminal convictions and offences.
HOW THE INFORMATION IS COLLECTED
We collect personal information through the application and recruitment process, either directly from candidates or sometimes from an employment agency. We may sometimes collect additional information from third parties including former employers or other background check agencies. We may collect additional personal information in the course of job-related activities throughout the period of you working for us.
WHEN WE WILL USE YOUR PERSONAL INFORMATION
We need all the categories of information identified 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). We will process your personal information as follows, the asterisks show the purpose for processing:
|Purpose||Type of data||Lawful basis|
|Making a decision about your recruitment or appointment.||1, 11, 12||***|
|Determining the terms on which you work for us.||7, 8, 9, 11, 12||***|
|Checking you are legally entitled to work in the UK.||1, 2, 5, 10||**|
|Paying you and, if you are an employee, deducting tax and National Insurance contributions.||1, 5, 6, 7||** *|
|[Providing benefits to you.||1, 2, 3, 4, 5, 6, 7, 8, 9||*|
|Liaising with your pension provider.||1, 2, 5, 7, 8||*|
|Administering the contract we have entered into with you.||1, 4, 5, 6, 7, 8, 9, 14, 15, 22||*** *|
|Business management and planning, including accounting and auditing.||1, 4, 5, 6, 7, 8, 9, 14, 15, 17, 20, 22, 23||***|
|Conducting performance reviews, managing performance and determining performance requirements.||1, 7, 8, 9, 14, 15, 16, 17, 22||*** *|
|Making decisions about salary reviews and compensation.||1, 6, 7, 8, 9, 11, 12, 14, 15, 16, 17||*** *|
|Assessing qualifications for a particular job or task, including decisions about promotions.||1, 11, 12, 14, 15, 22||*** *|
|Gathering evidence for possible grievance or disciplinary hearings.
Making decisions about your continued employment or engagement.
|1, 14, 15, 16, 17, 22
1, 14, 15, 16, 17, 22
|Making arrangements for the termination of our working relationship.||1, 5, 6, 7, 14, 15, 22||*** *|
|Education, training and development requirements.||1, 12, 14, 15, 22||*** *|
|Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.||1, 6, 7, 13, 14, 15, 16, 17, 18, 20, 21, 22, 24||***|
|Ascertaining your fitness to work and managing sickness absence.||1, 2, 3, 4, 9, 14,15, 16, 17, 20, 22||*** *|
|Complying with health and safety obligations.||1, 4, 9, 22||** *|
|To prevent fraud.||1, 5, 6, 10, 11, 12, 24||***|
|To monitor your use of our information and communication systems to ensure compliance with our IT policies.||1, 16, 17||***|
|To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.||1, 16, 17||***|
|To conduct data analytics studies to review and better understand employee retention and attrition rates.||1, 2, 3, 20, 22||***|
|Equal opportunities monitoring.||1, 2, 3, 20, 22||***|
FAILURE TO PROVIDE 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 employee benefits), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
SENSITIVE PERSONAL INFORMATION
“Special categories” of particularly sensitive personal information require higher levels of protection. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations and in line with our Data Protection Policy.
- Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our pension scheme, and in line with our Data Protection Policy.
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
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.
OUR OBLIGATIONS AS AN EMPLOYER
We will use your particularly sensitive personal information in the following ways:
- 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 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 national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may 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 our policies.
We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal information we hold about you is accurate and current, so please let us know if your information changes.
We may have to share your data with third parties, including third-party service providers (including contractors and designated agents); other entities in the group; in the context of a sale of the business; or with a regulator or to otherwise comply with the law; our insurers and/or professional advisers to manage risks legal disputes.
We do this 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.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We must store most of your HR data for a period of at least 6 years following the termination of your employment; some personal financial data will be destroyed after 2 years; Health and Safety information must be held for a minimum of 40 years.
Your rights in connection with 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”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Please refer to our DSAR Procedure for more information.
- 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 (see below).
- 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.
- 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.
- Request the transfer of your personal information to another party.
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. Please contact the person responsible for Data Protection in your Company.
COMPLAINTS & QUESTIONS
If you have any questions about this privacy notice or how we handle your personal information, please contact the person responsible for Data Protection in our Company. If we have breached our duty of care, we will take appropriate action.
If you are not satisfied by our response you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (Email: firstname.lastname@example.org)
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. We may also notify you in other ways from time to time about the processing of your personal information.