ࡱ> Y LbjbjPP Az2i2iD-ncncqqqqqqqq8Lq\q\qzr:>հհհ/t1$u//uuհհ6yyyuհհyuyy,!հ¯'~u/><z?9wH!!vquuyuuuuuxNuuuzuuuuuuuuuuuuuncX o: GRANTHAM INSITUTE PRIVACY NOTICE What is the purpose of this document? Թ College of Science, Technology and Medicine (the College or Թ) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the applicable data protection legislation the Data Protection Act 2018 and the General Data Protection Regulations (the GDPR) and the Colleges  HYPERLINK "http://www.imperial.ac.uk/admin-services/legal-services-office/data-protection/our-policy/" Data Protection Policy. The College is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. This notice applies to invitees to Grantham Institute organised events. It also applies to mailing list subscribers, research users and policy stakeholders with whom we may wish to engage in our research dissemination, knowledge exchange and other collaborative activities. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. Data protection principles We will comply with data protection law. This says that the personal information we hold about you must be: 1. Used lawfully, fairly and in a transparent way. 2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 3. Relevant to the purposes we have told you about and limited only to those purposes. 4. Accurate and kept up to date. 5. Kept only as long as necessary for the purposes we have told you about. 6. Kept securely.The kind of information we hold about you Personal data, or personal 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). There are "special categories" of more sensitive personal data which require a higher level of protection. We may 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. Professional details such as location of employment or workplace, your job role and organisation, telephone number and professional email address. How is your personal information collected? We collect the personal information about you via our online forms, via phone, in person and in the course of providing services to you or after we have provided services to you (e.g. feedback responses). We also collect publicly available personal information where it is available to us from publicly available sources. For example, this might include where contact details are published on websites. Depending on your privacy settings for social media services, we may access information from those accounts or services (for example when you choose to interact with us through platforms such as Facebook, LinkedIn or X). How we will use information about you and the legal basis for processing your data under the GDPR 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: Where it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us. 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. Where it is necessary in order to protect your vital interests or someone elses vital interests. Where you have consented to the processing.Situations in which we will use your personal information We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to perform a task carried out in the public interest or in the exercise of official authority vested in us. 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. ( To provide you with the information and services that you request from us. ( To contact you for the purposes of feedback. ( To notify you about changes to our service. ( Business management and planning, including accounting and auditing. ( Complying with health and safety obligations. ( To provide you with relevant news and special offers by email, phone or post where you have consented to receive this information. To disseminate our research findings to you To provide knowledge exchange opportunities to you (for example invitations to attend events and workshops that we think might be of interest). Occasionally publicise relevant competitions Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. If you fail to provide personal information If you fail to provide certain information when requested, we may not be able to accommodate you at our event. 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, in compliance with the above rules, where this is required or permitted by law. How we use particularly sensitive 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: 1. In limited circumstances, with your explicit written consent. 2. Where it is necessary in the context of employment law, or laws relating to social security and social protection. 3. Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent. 4. Where the processing is carried out in the course of our legitimate activities as a charity, with respect to our own members, former members, or persons with whom we have regular contact in connection with our purposes. 5. Where the processing relates to personal data which have been manifestly made public by you. 6. Where the processing is necessary for the establishment, exercise or defence of legal claims, or for courts acting in their judicial capacity. 7. Where the processing is necessary for reasons of substantial public interest, and occurs on the basis of a law that is, inter alia, proportionate to the aim pursued and protects your rights as a data subject. 8. Where the processing is required for the purpose of medical treatment undertaken by health professionals, including assessing the working capacity of employees and the management of health or social care systems and services. 9. Where the processing is necessary for reasons of public interest in the area of public health (e.g. ensuring the safety of medicinal products). 10. Where the processing is necessary for archiving purposes in the public interest, for historical, scientific, research or statistical purposes, subject to appropriate safeguards. Automated decision-making Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances: 1. Where we have notified you of the decision and given you 21 days to request a reconsideration. 2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. 3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.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. 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. Data sharing We may have to share your data with third parties, including third-party service providers and other entities in the College group. We require third parties to respect the security of your data and to treat it in accordance with the law. 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. 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 relationship with you or where we have another legitimate interest in doing so. Which third-party service providers process my personal information? "Third parties" includes third-party service providers (including contractors and designated agents) and other entities within the College group. The following activities are carried out by third-party service providers: On-line registration through Eventbrite How secure is my information with third-party service providers and other entities in our group? All our third-party service providers and other entities in the College group 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. What about 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 and operations of the College. We may also need to share your personal information with a regulator or to otherwise comply with the law. Data security We have put in place measures to protect the security of your information. 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. 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. 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. Data retention How long will you use my information for? 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 records the College holds are available in our retention policy which is available on this website:  HYPERLINK "http://www.imperial.ac.uk/media/imperial-college/administration-and-support-services/records-and-archives/public/RetentionSchedule.pdf" http://www.imperial.ac.uk/media/imperial-college/administration-and-support-services/records-and-archives/public/RetentionSchedule.pdf. 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. 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. Rights of access, correction, erasure, and restriction 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 relationship with us. 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. 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. 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 the Colleges Data Protection Officer in writing. 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. 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. 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 the Colleges Data Protection Officer. 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. Data Protection Officer We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer at: Թ Data Protection Officer Exhibition Road Faculty Building Level 4 London SW7 2AZ e-mail:  HYPERLINK "mailto:dpo@imperial.ac.uk" dpo@imperial.ac.uk 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 issues. 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.     V2.0 February 2024 PAGE1 !/G / 6 ? 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" # $ % & ' ( ) * + Oh+'0t  $ 0 < HT\dl Joyce ManNormalTaylor, Jamie2Microsoft Office Word@F#@pn@/~@/~C : ՜.+,D՜.+,T px  ThomsonReuters Document|#D  Title P)1 !- _PID_HLINKSContentTypeId TaxCatchAll!lcf76f155ced4ddcb4097134ff3c332fNotes@display_urn:schemas-microsoft-com:office:office#SharedWithUsersSharedWithUsersA8[mailto:dpo@imperial.ac.uk=yhttp://www.imperial.ac.uk/media/imperial-college/administration-and-support-services/records-and-archives/public/RetentionSchedule.pdf?*[http://www.imperial.ac.uk/admin-services/legal-services-office/data-protection/our-policy/,0x010100A363903AF0DAFF41A5D7368870B7731BBrandmayr, Caterina;Read, Laila A;Gilbert, Alyssa R;Taylor, Jamie;Thompson, Chloe;Oram, Debbie;Bird, Jennifer K;Vrkic, Dora;Field, Kate;Cannon, Claudia M847;#Brandmayr, Caterina;#13;#Read, Laila A;#14;#Gilbert, Alyssa R;#1109;#Taylor, Jamie;#1011;#Thompson, Chloe;#1129;#Oram, Debbie;#922;#Bird, Jennifer K;#873;#Vrkic, Dora;#1027;#Field, Kate;#169;#Cannon, Claudia M  !"#$%&'()*+,-./0123456789:;<=?@ABCDEGHIJKLMNOPQRSTUVWXYZ[\]^_`abcdefghijklmnopqrstuvwxyz{|}~Root Entry F(~@"Data >1TableFWordDocumentAzSummaryInformation(DocumentSummaryInformation8MsoDataStore *%~t'~1YLUEGSH2FXCXA0==2*%~%~Item  PropertiesO23H3NFH2CYS3KQ==2 *%~%~Item  Properties kIUVNLBCH24ZQ==2*%~ <&~Item S-Properties3NMZ1HGEMUHVWBMA==2 *%~@&~Item PropertiesSOCS1RUKGATNNS4==2*%~`&~Item  PropertiesA XQRLQECLNSGVQ==2*%~&'~Item ;Propertiesj}LZCU4A504QVDWA==2*%~t'~Item |3PropertiesZ !"#$%&'()*+,-./0123456789:;<=>?DocumentLibraryFormDocumentLibraryFormDocumentLibraryForm product.name0 GDPR Privacy notice for employees, workers and contractors (UK) Practical Law Employment Standard documents juris0 juris1 A privacy notice for employees, workers and contractors that complies with the EU General Data Protection Regulation (GDPR). Employers can use this notice to notify employees, workers and contractors about the personal data that the employer holds relating to them, how they can expect their personal data to be used and for what purposes.

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About this document The General Data Protection Regulation ((EU) 2016/679) (GDPR), adopted in May 2016, replaces the Data Protection Directive (95/46/EC) and will be directly applicable in all member states without the need for transposition on 25 May 2018. The GDPR requires employers to notify data subjects about their personal data handling practices through a privacy notice, at the time such data is collected. A privacy notice informs data subjects about how the organisation collects, uses, stores, transfers and secures personal data. This notice is stated to apply to employees, workers and contractors but may be adapted to reflect the staffing practices of the organisation. Some employers may wish to have a separate privacy notice for certain kinds of staff where separate and special considerations apply to them (for example, volunteers or interns). Training should be provided to staff who handle personal data across the organisation in relation to the new requirements under the GDPR and the issues arising in this standard document. At the recruitment stage, a short-form privacy notice should be issued to candidates in relation to the processing of their personal data for the purposes of the recruitment exercise (PL Employment will be drafting one in due course). It may be appropriate for the employer to issue separate short-form privacy notices periodically, setting out why data is being processed on a particular occasion and reminding the individual to refer to the contents of this notice. Before using this privacy notice, it is essential that the employer conducts a detailed data protection audit to ensure it understands how it uses, or plans to use, the personal data of employees, workers and contractors. For example, the employer must identify the types of personal data held, how it is collected and stored, any third parties to whom it is transferred and any cross-border transfers. The results of the audit should be documented. For further information, see Checklist, GDPR compliance for employers: Employee data audit. The privacy notice must also be tailored on a case-by-case basis for each organisation, in the light of the results of the data protection audit. No template notice can be appropriate for all employers. This standard document suggests various examples under each heading, but employers must ensure that each part of the privacy notice accurately reflects actual or anticipated personal data collection and handling practices. Format of this notice Under Article 13 of the GDPR, an employer is required to provide the individual with certain information at the point their information is collected (see Drafting note, Provision of information to data subjects). All information provided must be concise, transparent, easily accessible and given in plain language (Article 12, GDPR). It remains to be seen how this presentational requirement will be interpreted by the Information Commissioner. There is an inherent tension between the requirement to provide extensive information to individuals and the conciseness requirement. With this in mind, employers may wish to adapt this notice for internal use on their intranet (if they have one), providing links to certain sections which lend themselves to being clicked through to rather than setting everything out in full in one document. For example, rather than providing a list of personal information as set out below, an extended list might instead be provided via a link. The same approach might be taken in respect of the list of purposes for which personal information might be processed and, where considered appropriate, in respect of other sections. Provision of information to data subjects The GDPR requires the employer to provide the data subject with the following information: The data controller's identity (meaning the name of the legal entity) and contact details and its representative, if any. The contact details of the data protection officer (DPO), where applicable. The intended purposes of, and the legal basis for, the processing. Where the processing is based on Article 6(1)(f) of the GDPR (legitimate interest), the legitimate interest pursued by the employer or by a third party (see Drafting note, Use of personal information). The recipients or categories of recipients of the personal data, if any. Where applicable, the fact that the employer intends to transfer the personal data to a recipient in a country outside the EU or an international organisation, and the existence or absence of a Commission adequacy decision or information about the appropriate or suitable safeguards adduced to secure the data and the means to obtain a copy of them or where they have been made available. (Article 13(1).) The employer must also provide the data subject with the following information to ensure fair and transparent processing: The period for which the personal data will be stored, or the criteria used to determine that period. The existence of the individual's: right of access (Article 15, GDPR); right to rectification (Article 16); right to erasure (Article 17); right to restriction of processing (Article 18); right to object to processing (Article 21); and right to data portability (Article 20). Where processing is based on the individual's consent, the right to withdraw that consent at any time. The individual's right to lodge a complaint with the supervisory authority. Whether the provision of personal data is a statutory or contractual requirement or a requirement necessary to enter into a contract. The individual must be informed about any obligation to provide personal data and of the consequences of a failure to do so. The existence of automated decision-making or profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual. (Article 13(2).) For details of the information to be provided to individuals when personal data is collected from a third party, see Drafting note, How is your personal information collected?. The ICO has issued guidance on drafting privacy notices, which has been updated to refer to the GDPR (see ICO guidance: Privacy notices, transparency and control). UK-specific rules Article 6(2) of the GDPR grants member states a limited right to maintain or introduce more specific provisions to adapt the application of the GDPR with regard to data processing for: Compliance with a legal obligation (Article 6(1)(c)). The performance of a task carried out in the public interest or in the exercise of official authority (Article 6(1)(e)). The UK has done so by means of the Data Protection Bill (DPB). For more information on the DPB, see Practice note, The GDPR and Data Protection Bill: employer obligations and Data Protection Bill tracker. Organisations with employees, workers and contractors in multiple jurisdictions face compliance challenges when trying to implement staff privacy notices as part of a global privacy compliance program. Multi-national employers must choose between implementing a single, global privacy notice for its workforce or jurisdiction-specific or regional privacy notices, taking into account the fact that even within the EU member states are likely to have varying rules on data protection. For more information on the legal framework governing employee personal data under the GDPR, see Practice Note, Overview of EU General Data Protection Regulation and Toolkit, Data protection in employment under the GDPR and DPB. What is the purpose of this document? What is the purpose of this document? This privacy notice applies to current and former employees, workers and contractors. It makes the individual aware of how and why their personal data will be used. It provides the individual with certain information that must be provided under the GDPR (see Drafting note, Provision of information to data subjects). A separate privacy notice should be provided to applicants at the recruitment stage. If applicants are not successful, then the majority of the contents of this privacy notice will not be applicable. It may be appropriate for the employer to issue separate short-form privacy notices periodically, setting out why data is being processed on the particular occasion and reminding the individual to refer to the contents of this notice. [EMPLOYER] is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all employees, workers and contractors.
[EMPLOYER] is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. Data protection principles Data protection principles The GDPR sets out principles with which data controllers and processors must comply when       !"#$%&'()*+,-./0123456789:;<=>?@ABCDEFGHIJKLMNOPQRSTUVWXYZ[\]^_`abcdefghijklmnopqrstuvwxyz{|}~processing personal data (Article 5). These principles form the core of the obligations of the data controller and will usually form the basis of any claim that a data controller has not complied with its statutory duties. For further information, see Practice note, Overview of EU General Data Protection Regulation: Data protection principles. We will comply with data protection law. This says that the personal information we hold about you must be: 1. Used lawfully, fairly and in a transparent way. 2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 3. Relevant to the purposes we have told you about and limited only to those purposes. 4. Accurate and kept up to date. 5. Kept only as long as necessary for the purposes we have told you about. 6. Kept securely.
The kind of information we hold about you Collecting personal data The GDPR defines personal data as "any information relating to a data subject" (Article 4(1)). A data subject is the identified or identifiable person to whom the personal data relates and, in relation to this document, is the employee, worker or contractor. Employers should include a broad definition of personal data in their privacy notices and identify any categories of data that do not constitute personal data so that these can be excluded. For example, anonymous data, or data where the identity of the individual has been irretrievably removed, would not be considered personal data. The categories of data included in this privacy notice provide examples only and are not intended to be an exhaustive list of all of the categories of personal data that an employer may collect. Employers must tailor the categories of personal data listed to reflect their actual data collection practices (based on the results of their data protection audit). Personal data, or personal 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). There are "special categories" of more sensitive personal data which require a higher level of protection.
We may 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.] [Gender.] [Marital status and dependants.] [Next of kin and emergency contact information.] [National Insurance number.] [Bank account details, payroll records and tax status information.] [Salary, annual leave, pension and benefits information.] [Start date.] [Location of employment or workplace.] [Copy of driving licence.] [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).] [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.] [Photographs.] We may also collect, store and use the following "special categories" of more sensitive personal information: [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.] [Genetic information and biometric data.] [Information about criminal convictions and offences.] How is your personal information collected? How is your personal information collected? Organisations should ensure that any personal data collected from third parties is listed here. Additional notification requirements apply to personal data collected from parties other than the individual directly (Article 14(1), GDPR). These mirror the notification requirements in respect of data collected directly from the employee (see Drafting note, Provision of information to data subjects), save that the following information must also be notified: The categories of personal data concerned. The source of the personal data and, if applicable, whether it came from publicly accessible sources. This information must be provided to the individual within a reasonable period after obtaining the data but at the latest within one month. However, if the personal data is to be used for communication with the individual before such time, the information must be provided at the latest at the time of the first communication with them. If the personal data is to be disclosed to another recipient, the information must be provided to the individual before such disclosure takes place. This privacy notice should be tailored to ensure that it refers to all sources of personal data other than the individuals themselves and, where possible, the notice should include the information set out in the two bullet points above. If this is not possible in the privacy notice itself, a separate notification must be given to the individual at the appropriate time. We typically collect personal information about employees, workers and contactors 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 [LIST OTHERS]. We will collect additional personal information in the course of job-related activities throughout the period of you working for us. How we will use information about you How we will use information about you Lawful basis for processing The suggested uses of personal data included in this privacy notice are examples and are not intended to be an exhaustive list of all of the reasons an employer may process personal data. The employer should tailor the list to reflect its practices. An employer which bases personal data processing on its own legitimate interests must identify the legitimate interests in the privacy notice. The GDPR requires a data controller to justify the processing of personal data before it will be considered lawful under Article 5(1)(a) (see Drafting note, Data Protection principles). An employer must only process personal data on the basis of one or more of the following legal grounds: The individual has given their consent to the processing of their data for one or more specific purposes (Article 6(1)(a)). However, the ICO's draft guidance on consent indicates that employers will find it difficult to rely on consent in the employment context. For further information on consent, see Practice notes, The GDPR and Data Protection Bill: employer obligations: Employee consent and Overview of EU General Data Protection Regulation: Consent requirements. It is necessary for entering into or performing a contract with the individual (Article 6(1)(b)). It is necessary for compliance with a legal obligation to which the data controller is subject (Article 6(1)(c)). It is necessary to protect the vital interests of the individual or another person (Article 6(1)(d)). It is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the employer (Article 6(1)(e)). It is necessary for the purposes of legitimate interests pursued by the employer or by a third party, except where these interests are overridden by the interests or the fundamental rights and freedoms of the individual which require protection of personal data (Article 6(1)(f)). Matching categories of personal data with processing grounds This notice sets out (suggested) situations in the employment or working lifecycle in which personal information will be processed. It is likely that strict compliance with the GDPR requires each category of personal data used in the lifecycle to be matched with a particular processing purpose or purposes. It remains to be seen what view the ICO will take of a privacy notice which sets out processing grounds in more general terms. It is an option for the employer to set out the correlation between the personal information and the purpose or purposes by using asterisks within this notice. One type of personal data may be processed for more than one purpose and where this occurs, this should be made clear. For more information on personal data processing under the GDPR, see Practice note, Overview of EU General Data Protection Regulation. Change of purpose If the employer wants to use personal data for new or different purposes that are not compatible with the original purposes of use, the employer will need to consider whether there is a lawful basis for the processing for the new purpose (Article 13(4), GDPR). As a general rule under the GDPR, the purpose limitation principle binds the employer to the specified, explicit and legitimate purposes notified to the individual on collection of the personal data (Article 5(1)(b)). Organisations may process personal data for purposes other than those for which the data was initially collected where either: They can identify another legal basis for personal data processing under Article 6(1) (see Drafting note, How we will use information about you). The processing is compatible with the original purposes of use. When ascertaining whether a purpose of further processing is compatible with the one for which the data was originally collected, employers must take into account the following non-exhaustive list of criteria: Any link between the purposes for which the personal data has been collected and the purposes of the intended further processing. The context in which the personal data has been collected, in particular regarding the relationship between the individual and the employer. The nature of the personal data, in particular whether special categories of personal data are processed, or whether personal data related to criminal convictions and offences is processed. The possible consequences of the intended further processing for individuals. The existence of appropriate safeguards, which may include encryption or pseudonymisation. (Article 6(4).) The GDPR includes two notable exceptions that permit further processing where the new processing activity is incompatible with that original purpose, namely: Further processing with the individual's consent (Article 6(4)). Further processing on the basis of EU or domestic law which constitutes a necessary and proportionate measure in a democratic society to safeguard the objectives referred to in Article 23(1), which include national security (Article 6(4)) (see Practice note, Overview of EU General Data Protection Regulation: National derogations). If an employer wants to use previously collected data for a new or different purpose that is unrelated to the original purpose, in most circumstances, it must provide a revised notice to individuals (Article 13(3)). 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: 1. Where we need to perform the contract we have entered into with you. 2. Where we need to comply with a legal obligation. 3. 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. We may also use your personal information in the following situations, which are likely to be rare: 1. Where we need to protect your interests (or someone else's interests). 2. Where it is needed in the public interest [or for official purposes].
Situations in which we will use your personal information We need all the categories of information in the list above (see The kind of information we hold about you) 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. [We have indicated by [asterisks] the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.] [Making a decision about your recruitment or appointment.] [Determining the terms on which you work for us.] [Checking you are legally entitled to work in the UK.] [Paying you and, if you are an employee, deducting tax and National Insurance contributions.] [Providing the following benefits to you: [LIST].] [Liaising with your pension provider.] [Administering the contract we have entered into with you.] [Business management and planning, including accounting and auditing.] [Conducting performance reviews, managing performance and determining performance requirements.] [Making decisions about salary reviews and compensation.] [Assessing qualifications for a particular job or task, including decisions about promotions.] [Gathering evidence for possible grievance or disciplinary hearings.] [Making decisions about your continued employment or engagement.] [Making arrangements for the termination of our working relationship.] [Education, training and development requirements.] [Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.] [Ascertaining your fitness to work.] [Managing sickness absence.] [Complying with health and safety obligations.] [To prevent fraud.] [To monitor your use of our information and communication systems to ensure compliance with our IT policies.] [To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.] [To conduct data analytics studies to review and better understand employee retention and attrition rates.] [Equal opportunities monitoring.] Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. 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). 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, in compliance with the above rules, where this is required or permitted by law. How we use particularly sensitive personal information How we use particularly sensitive personal information Special categories of personal data Subject to certain exceptions, the GDPR prohibits the processing of "special categories of personal data". This is personal data that reveals: Racial or ethnic origin. Political opinions. Religious and philosophical beliefs. Trade union membership. Genetic data. Biometric data. Health data. Sex life and sexual orientation. (Article 9(1).) Justifications for processing special categories of employee personal data An employer may only process the special categories of personal data in the following circumstances: Explicit consent from the individual. The processing is necessary for the employer to carry out specific rights and obligations in the context of employment law, such processing is authorised by domestic or EU law and the employer has an appropriate policy document in place (section 9, paragraph 1, Schedule 1 and Part 4, Schedule 1, DPB). The processing is necessary to protect the vital interests of the individual or another person and the individual is incapable of giving consent. The processing is carried out by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim, provided that the processing relates only to members or former members and provided there is no disclosure to a third party without the consent of the data subject. If the employer does not fall into this category, the wording in square brackets should be removed from the privacy notice. The processing relates to personal data that the individual made public. The processing is necessary for establishing, exercising, or defending legal claims. The processing is necessary for reasons of substantial public interest as provided in domestic or EU law. Provided that the employer has an appropriate policy document in place, this can include: processing of personal data revealing race, religious beliefs, health or sexual orientation for the purposes of promoting equality of treatment (Section 9, paragraph 7, Schedule 1 and Part 4 Schedule 1, DPB); and processing necessary to determine eligibility for or benefits payable under an occupational pension scheme which can reasonably be carried out without the individual's consent being provided (Section 9, paragraph 16, Schedule 1 and Part 4 Schedule 1, DPB). The processing is necessary for the assessment of the individual's working capacity either on the basis of domestic or EU law or pursuant to a contract with a health professional, and subject to confidentiality safeguards (Section 9 and paragraph 2, Schedule 1, DPB and Article 9(3)). (Article 9(2).) The special categories of personal data and the purposes of use that are included in this privacy notice provide examples only and are not intended to be an exhaustive list of all of the reasons an employer may use the special categories of personal data. The employer should tailor the special categories of personal data collected and the purposes of use listed to reflect its practices, and must ensure that there is a lawful justification permitting its use of special categories of personal data. "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: 1. In limited circumstances, with your explicit written consent. 2. Where we need to carry out our legal obligations and in line with our [data protection policy OR [POLICY]]. 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 OR [POLICY]]. 4. 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. [We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.] [LIST ANY OTHER.] Do we need your consent? 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. Information about criminal convictions Information about criminal convictions The GDPR provides additional safeguards in connection with the processing of personal data relating to criminal convictions and offences. This personal data may only be processed under the control of official authority or when the processing is authorised by EU or domestic law which provides for appropriate safeguards for the rights and freedoms of data subjects (Article 10). In the UK, employers may only seek information about a person's criminal record history through voluntary disclosure or through official criminal records checks through the Disclosure and Barring Service (DBS). For details of the circumstances in which an employer is allowed to carry out a criminal records check through the DBS, see Practice note, Carrying out criminal records checks. The DPB imposes further requirements when an employer wishes to process personal data relating to criminal convictions or offences. Such processing is permitted if one of the conditions in Part 1, Part 2 or Part 3 of Schedule 1 of the DPB is satisfied. Those most relevant to the employment context are: The processing is necessary for the purposes of carrying out employment rights and obligations and the employer has an appropriate policy document in place (paragraph 1 and Part 4, Schedule 1, DPB). The individual has given their consent (paragraph 22, Schedule 1, DPB). The processing is necessary to protect the vital interests of the individual or another person where the individual is incapable of giving consent (paragraph 23, Schedule 1, DPB). Processing by a foundation, association or not-for-profit with a political, philosophical, religious or trade union aim, provided that the processing relates solely to members or former members or persons who have regular contact in connection with its purposes and the personal data is not disclosed to third parties without the data subject's consent (paragraph 24, Schedule 1, DPB). If the individual has made the personal data public (paragraph 25, Schedule 1, DPB). The processing is necessary for the employer to establish or defend legal claims (paragraph 26, Schedule 1, DPB). For the majority of employers who do not process any personal data relating to criminal convictions or offences, this section should simply include the first statement confirming that the employer does not envisage holding any such information. The remainder of this section may be omitted. Those employers who do process criminal convictions data should set out here the nature of the processing and the lawful justification for doing so. 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 [data protection policy OR [POLICY]]. Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary 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.]
We [envisage OR do not envisage] that we will 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.] [We will use information about criminal convictions and offences in the following ways: [LIST].] [We are allowed to use your personal information in this way [to carry out our obligations [SPECIFY] OR [SET OUT OTHER LAWFUL BASIS]].] Automated decision-making Automated decision-making Under the GDPR, individuals have a right not to be subject to decisions based on automated data processing if the decisions produce legal effects on the individual or significantly affect them. (Article 22(1) and Recital 71). Examples of where such decisions may be made in the employment context are: Automatic rejection of candidates in online recruitment systems if they do not have the requisite qualifications or grades. A "trigger" is met in a sickness absence or disciplinary procedure. A bonus decision is made on the basis of attendance data alone. Automatic shift and holiday rostering. Monitoring of employee emails and internet use. If an employer is able to identify as a result of the data protection audit that automated decision-making does take place, this privacy notice should include full details. There are exemptions to this rule if the automated decision-making is necessary for entering into or performing the contract or is based on the individual's explicit written consent, and the employer has implemented measures to safeguard the individual's rights and freedoms and legitimate interests. These must include the right to human intervention, to express their point of view and appeal the decision. (Article 22(2).) Additionally, the DPB provides further lawful justifications for automated decision-making to take place. It will be permitted if the employer notifies the individual in writing as soon as reasonably practicable that a decision has been taken based solely on automated processing and gives the individual a period of 21 days to request a reconsideration or that a new decision is taken not based solely on automated processing. In the event such a request is made, the employer must consider the request and comply with it, and inform the individual of the outcome in writing. (Section 13, DPB.) This privacy notice specifically states that the individual will not be subject to any automated decision-making unless there is a lawful justification which has been notified to them. This is one of the Article 13(2) requirements. For more information, see Drafting note, Provision of information to data subjects. For more information on automated data processing under EU law, see Practice notes: Overview of EU General Data Protection Regulation: Measures based on profiling. The GDPR and Data Protection Bill: employer obligations: Automated decision-making (including profiling). Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances: 1. Where we have notified you of the decision and given you 21 days to request a reconsideration. 2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. 3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
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. [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.] Data sharing Data sharing Under Article 28 of the GDPR, the employer is required to enter into a contract (or other legally binding act) with any third-party processor that imposes obligations on the processor to: Process the personal data only on the documented instructions of the employer. Only use staff and other persons who have a duty of confidentiality with regard to the data. Comply with security obligations equivalent to those imposed on the employer under the GDPR. Notify the employer of any breach in relation to the personal data shared by the employer. Enlist a sub-processor only with the prior permission of the employer. For further information, see Practice note, Data processor obligations under the GDPR: Overview. Cross-border data transfers An employer may wish to transfer the personal data of their employees, workers and contractors across international borders where they have offices or other legal entities in different jurisdictions, or where the employer is part of an international group of companies. The employer may also use external service providers (such as IT providers) in other jurisdictions and workforce personal data may need to be transferred to those third parties for the performance of the services. The GDPR restricts transfers of personal data outside the EU unless the recipient country provides adequate protection for the personal data, or other safeguards are in place. This is to ensure that the level of protection of an individual's personal data afforded by the GDPR is not undermined. After Brexit, the UK will be a jurisdiction outside the EU. This notice should be reviewed on an ongoing basis as the UK progresses towards Brexit to ensure it is still applicable in its current form after Brexit and to ensure that there are no national or EU laws in place in other member states that would affect the transfer of personal data between the UK and any relevant member state. In relation to data transfers to EU countries, the notice is likely to need to contain details of the lawful basis for doing so (for example, an adequacy decision by the European Commission (if one is in place)). Personal data can only be transferred outside the EU to third countries or international organisations in compliance with the conditions for transfer set out in Chapter V (Articles 44-50) of the GDPR, namely where one of the following applies: There has been an adequacy decision by the European Commission in relation to the third country, territory or specific sector. Adequate safeguards have been provided by the employer or third-party-processor. These may be provided by way of: a legally binding and enforceable instrument between public authorities; binding corporate rules (BCRs) (BCRs may be used within the same corporate group and can also be used by a group of enterprises engaged in a joint economic activity); standard contractual clauses adopted by the Commission; standard contractual clauses adopted by a supervisory authority and approved by the Commission; an approved code of conduct; or an approved certification mechanism. In cases of transfer of personal data to the US, the third party participates in self-certification with the EU-US Privacy Shield. A derogation applies. Article 49 of the GDPR sets out a limited number of derogations which can be used for data transfers in the absence of adequacy determinations, appropriate safeguards or the EU-US Privacy Shield. Where personal data is to be transferred to a country outside the EU, the individual has the right to be informed of the appropriate safeguards in place (Article 15(2)). This notice includes an optional clause (to be used when data is to be transferred to third parties outside the EU) which provides for details of the safeguards to be requested from a designated person, or else directs the individual to an intranet or relevant link on the intranet. For further information, see Practice note, Overview of EU General Data Protection Regulation: Cross-border data transfers. We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. 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.
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. Which third-party service providers process my personal information? "Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. [The following activities are carried out by third-party service providers: [payroll, pension administration, benefits provision and administration, IT services] OR The following third-party service providers process personal information about you for the following purposes: [NAME PROVIDERS AND THE ACTIVITY THEY CARRY OUT]]. How secure is my information with third-party service providers and other entities in our group? All our third-party service providers and other entities in the group 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. When might you share my personal information with other entities in the group? We will share your personal information with other entities in our group [as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data [DESCRIBE OTHER KNOWN ACTIVITIES]]. What about 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. Transferring information outside the EU We may transfer the personal information we collect about you to the following [country OR countries] outside the EU [LIST] in order to perform our contract with you. There [is OR is not] an adequacy decision by the European Commission in respect of [that OR those] [country OR countries]. This means that the [country OR countries] to which we transfer your data are [deemed OR not deemed] to provide an adequate level of protection for your personal information. However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure[s] to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection: [SPECIFY MEASURE, FOR EXAMPLE, BINDING CORPORATE RULES]. If you require further information about [this OR these] protective measure[s], [you can request it from [POSITION] OR it is available [ON THE INTRANET/PROVIDE LINK HERE].] Data security Data security Organisations must: Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected (Article 32(1), GDPR). Ensure that anyone acting under their authority who has access to the personal data does not process it except on their instructions, unless required to do so by EU or member state law (Article 32(4)). Security measures Measures that may be taken include or display the following features and functionalities: The pseudonymisation and encryption of personal data. The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services. The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident. A process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. (Article 32(1).) For further information on security measures under the GDPR, see Practice note, Overview of EU General Data Protection Regulation. We have put in place measures to protect the security of your information. Details of these measures are available [upon request OR on the intranet]. 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.
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 [POSITION].] 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. Data retention Data retention The GDPR does not specify retention periods for personal data. Instead, employers are required not to retain personal data in a form that enables members of its workforce to be identified for longer than is necessary to fulfil the purposes the employer collected it for (Article 5(1)(e)). Article 30 of the GDPR introduces documentation requirements for data controllers such that they must maintain a record of all processing operations under their responsibility, which includes, where possible, a general indication of the time limits for erasure of the different categories of data. Article 13(2) requires the employer to provide the individual with information about the period for which the data will be stored (as part of the transparency principle). If this is not available, the criteria used to determine that period should be provided. If an employer has a retention policy, it may wish to link to this from the privacy notice. For a suggested retention policy, see Retention of employment records. How long will you use my information for? 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 available in our retention policy which is available from [[POSITION] OR [THE INTRANET/PROVIDE LINK]]. 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. 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 [our data retention policy OR applicable laws and regulations]. Rights of access, correction, erasure, and restriction Rights of access, rectification, erasure, and restriction Data subject access requests (DSARs) Under the GDPR, individuals have the right to obtain confirmation from their employer as to whether or not the employer processes personal data relating to them. If the employer does process the individual's personal data, it must provide them with access to the data, including providing a copy of the personal information (unless providing a copy adversely affects the rights and freedoms of others) (Article 15). The employer must also provide: Information as to the purposes of the processing. The categories of personal data concerned. The recipients or categories of recipients to whom the personal data has been or will be disclosed (in particular outside the EU). The envisaged period for which the personal data will be stored (or the criteria used to determine that period). Information on the existence of the right to request rectification, erasure or restriction of processing. Information on the right to object to processing and the right to lodge a complaint with the ICO. Information as to the source of the personal data (where it has not been collected from the individual). Information about the logic involved in any automated decision-making, as well as the significance and envisaged consequences of such processing for the individual (Article 15(1).) The employer must provide a copy of the personal data it processes to the individual free of charge. When the individual makes the request electronically, the employer must provide the information in a commonly used electronic form, unless the individual requests the information in a different format. The employer may charge a reasonable fee for additional copies (Article 15(3)). If an individual's requests are unfounded or excessive, the employer may either: Charge a reasonable fee to provide the information or take the requested action. Refuse to act on the request. (Article 12(5).) If the employer or its third-party processor transfers the personal data to a third country outside the EU or to an international organisation, they must inform the individual of the appropriate safeguards in relation to the transfer (Article 15(2)). (See Practice note, EU General Data Protection Regulation: implications for employers.) Right to rectification Based on the principle set out in Article 5(d) that personal data must be kept accurate and up to date (see Drafting note, Data Protection principles), the individual has the right to request the employer to: Rectify any personal data relating to them that is inaccurate. Complete any incomplete data, including by way of providing a supplementary statement. (Article 16.) Right to erasure ("right to be forgotten") Individuals have the right to the erasure of personal data held by the employer without undue delay. The employer must comply with any such request, if one of the following grounds applies: The data is no longer necessary in relation to the purposes for which it was collected or otherwise processed. The individual withdraws consent on which the processing is based, and there is no other legal ground for the processing of the data. The individual objects to the processing of personal data pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing (see Practice note, Overview of EU General Data Protection Regulation: Processing for public interest purposes and the controller's legitimate interest). The individual objects to the processing of their data for direct marketing purposes (including profiling to the extent that it is related to direct marketing). The personal data has been unlawfully processed. The personal data has to be erased for compliance with a legal obligation under EU or domestic law. (Article 17(1).) Article 17(2) includes a new "right to be forgotten". This requires the data controller to erase personal data and to inform other controllers that are processing the personal data that the data subject has requested erasure by them of any links to, or copies of, that data. Employers are not required to erase the data or inform third party controllers of the individual's request to the extent that the processing is necessary for any of the following reasons: Exercising the right of freedom of expression and information. Compliance with a legal obligation which requires processing by EU or domestic law or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. For reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3) (see Drafting note, Special categories of personal data). For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), insofar as the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing. For the establishment, exercise or defence of legal claims. (Article 17(3).) Right to object to processing Individuals have the right to object to processing, on grounds relating to their particular situation, where the processing is based on the employer's legitimate interests or those of a third party. This includes the situation where profiling takes place. If such a request is made, the employer must stop processing such data unless the employer can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the individual. Alternatively the employer may continue processing if it is necessary for the establishment, exercise or defence of legal claims. Individuals can also object to processing of data where it takes place for direct marketing purposes. It would be unusual for the employer to process employee data for direct marketing purposes, but where this takes place and the employee objects, the personal data shall no longer be processed for such purposes. (Article 21 GDPR.) Restriction of processing Individuals have the right to obtain a restriction of processing by their employer in certain circumstances (Article 18, GDPR). The right to restriction of processing exists where one of the following conditions applies: The individual contests the accuracy of the data. The individual can request the data to be restricted for a period to enable the employer to verify the information. The processing is unlawful and the individual opposes the erasure of the data and chooses restriction instead. This could be the case where the individual wishes to secure the data for evidential purposes. The employer no longer needs the data for its own purposes but is required to retain it by the individual for the establishment, exercise or defence of legal claims. The individual has objected to processing pending verification as to whether the legitimate grounds of the employer override those of the individual (see Practice note, Overview of EU General Protection Regulation: Right to object to processing). (Article 18(1).) "Restriction of processing" means that the employer has the continued right to store an individual's personal data, but may only process it in one of the following circumstances: With the individual's consent. For the establishment, exercise or defence of legal claims. For the protection of the rights of another natural or legal person. For important public interest reasons. In cases where an individual has obtained a restriction, the employer must inform the individual before the restriction is lifted (Article 18(3)). Obligation to notify The employer must also communicate any rectification, erasure or restriction of processing to each recipient to whom it has disclosed the personal data, unless this proves impossible or involves disproportionate effort (Article 19, GDPR). Right to data portability Article 20 of the GDPR introduces a new right to data portability. This means that the individual has the right to: Obtain from the employer, on request, a copy of all personal data, which he or she has provided to the employer, where the processing is: based on the individual's consent (Article 6(1)(a) and Article 9(2)) or necessary to carry out the contract with the individual (Article 6(1)(b)); and carried out by automated means. Transmit the data to another data controller (Article 20(2)). The employer must provide the data in a structured, electronic format that is commonly used and permits further use by the individual. Time limits for employer to respond Employers need to ensure that they have up to date and effective policies and processes in place to respond to any data subject access requests, rectification, erasure, restriction of or objection to processing or data portability requests from individuals and that their systems can deal with such requests. Under Article 12(3) the employer must respond to the individual in respect of the rights asserted above "without undue delay and in any event within one month of receipt of the request". This is extendable by a further two months taking into account the complexity and number of requests. Therefore, it could be prudent for an employer to liaise with the individual to clarify and ascertain exactly what the individual is seeking, where necessary, so that the request is clear and specific, failing which the employer may be entitled to respond within three months instead of one month. For information on data subjects' rights under the GDPR, including the right to be forgotten and the right to data portability, see Practice note, Overview of EU General Data Protection Regulation: Rights of data subject. 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. 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. 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. 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 [POSITION] in writing. 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. 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. Right to withdraw consent Right to withdraw consent Under the GDPR, if an employer bases data processing on consent, the individual has the right to withdraw consent at any time without any justification, although this will not affect the lawfulness of any processing carried out before the withdrawal (Article 7(3)). Data subjects must be informed of their right to withdraw their consent and consent must be as easy to withdraw as it is to give. If an individual withdraws consent, the employer could face a situation where it can no longer process the personal data in question because the employer does not have another legal ground for processing. For more information on the use of consent under the GDPR, and the difficulties faced in the use of consent in the employment context, see Practice note, The GDPR and Data Protection Bill: employer obligations: Employee 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 [POSITION]. 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. Data protection officer Data protection officer (DPO) Although some employers will appoint DPOs voluntarily, there is only a requirement under the GDPR for a DPO to be designated in any of the following circumstances: Where the processing is carried out by a public authority or body, except for courts acting in their judicial capacity. Where the core activities of the controller or the processor consist of processing operations which, by virtue of their nature, their scope and their purposes, require regular and systematic monitoring of data subjects on a large scale. Where the core activities of the controller or the processor consist of processing any special categories of personal data on a large scale and data relating to criminal convictions and offences (Articles 9 and 10). (Article 37(1).) Irrespective of whether a mandatory DPO needs to be appointed, most organisations will want to allocate data privacy compliance to a particular individual. They may be called a data privacy manager, if they are not a DPO, to make clear that DPO rights do not apply to them. For more information on DPO requirements under the GDPR, see Practice note, The GDPR and Data Protection Bill: employer obligations: Data protection officer (DPO). [We have appointed a [data protection officer (DPO) OR data privacy manager] to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the [DPO OR data privacy manager]. 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 issues.] 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. If you have any questions about this privacy notice, please contact [POSITION AND CONTACT DETAILS]. Acknowledgment of receipt The GDPR does not require the employer to sign an acknowledgment of receipt. However, as best practice, employers often request that employees sign an acknowledgment to demonstrate that they have been properly informed of their data collection and handling practices, including any data subject rights, such as access rights. I,___________________________ (employee/worker/contractor name), acknowledge that on _________________________ (date), I received a copy of [EMPLOYER]'s Privacy Notice for employees, workers and contractors and that I have read and understood it. Signature …ĦĦĦĦĦĦĦĦĦĦĦĦĦĦĦĦĦ Name …ĦĦĦĦĦĦĦĦĦĦĦĦĦĦĦĦĦ…
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