Last Updated: 15th September 2020

Data Protection Policy of (“Our Site”)

IMPORTANT: Our Data Protection Manager at the time off issuing this policy is Antony Morton. Any
questions about this policy should be addressed to them. If they are no longer the Data Protection
Manager, you can find out who is by contacting Vikki Wild.

1. Overview
1.1 We need to gather and use information or ‘data’ about you as part of our business and to
manage our relationship with you. This policy sets out the things we must tell you about data

1.2 We take the security and privacy of your data seriously and intend to comply with our legal
obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data
Protection Regulation (‘GDPR’) in respect of data privacy and security.

1.3 This policy applies to current and former employees, workers, volunteers, apprentices, and
consultants. If you fall into one of these categories, then you are a ‘data subject’ for the
purposes of this policy. You should read this policy alongside your employment contract (or
contract for services) and any other notice we issue to you from time to time in relation to
your data.

1.4 The Company has separate policies and privacy notices in place in respect of job applicants,
customers, suppliers, and other categories of data subject. Copies can be obtained from
Antony Morton.

1.5 We will only hold data for as long as necessary for the purposes for which we collected it.

1.6 The Company is a ‘data controller’ for the purposes of your personal data. This means that we
decide how and why we process your personal data.

1.7 This policy explains how we will hold and process your information. It explains your rights as
a data subject. It also explains your obligations when obtaining, handling, processing, or
storing personal data in the course of working for, or on behalf of, the Company.

1.8 This policy does not form part of your employment contract (or contract for services, if
relevant) and we may update it at any time. It is intended that this policy is fully compliant
with the 2018 Act and the GDPR. If any conflict arises between those laws and this policy, the
Company intends to comply with the 2018 Act and the GDPR.

2. Data Protection Principles
a. Personal data must be processed in accordance with the following ‘Data Protection
Principles.’ It must:
i. be processed fairly, lawfully and transparently;
ii. be collected and processed only for specified, explicit and legitimate purposes;
iii. be adequate, relevant, and limited to what is necessary for the purposes for which it is
iv. be accurate and kept up-to-date. Any inaccurate data must be deleted or rectified
without delay;
v. not be kept for longer than is necessary for the purposes for which it is processed; and
vi. be processed securely.

We are responsible for ensuring and demonstrating compliance with these principles.

3. How we define personal data
a. ‘Personal data’ means information which relates to a living person who can be identified from
that data (a ‘data subject’) on its own, or when taken together with other information which
is likely to come into our possession. It includes any expression of opinion about the person
and an indication of the intentions of us or others, in respect of that person. It does not include
anonymised data.

b. This policy applies to all personal data whether it is stored electronically, on paper, or in/on
other materials.

c. This personal data might be provided to us by you, or by someone else (such as a former
employer, your doctor, or a credit reference agency), or it could be created by us. It could be
provided or created during the recruitment process or during the course of the employment
contract (or contract for services) or after it has ended. It could be created by your manager
or other colleagues.
d. We will collect and use the following types of personal data about you:
i. Recruitment information such as your application form and CV, references,
qualifications and membership of any professional bodies and details of any preemployment assessments.
ii. Your contact details and date of birth.
iii. The contact details for your emergency contacts.
iv. Your gender.
v. Your marital status and family details.
vi. Information about your employment contract (or contract for services) including start
and end dates of employment, role, and location, working hours, details of promotion,
salary (including details of previous remuneration), pension, benefits, and holiday
vii. Your bank details and information in relation to your tax status including your National
Insurance number.
viii. Your identification documents including passport and driving licence and information in
relation to your immigration status and right to work for us.
ix. Your medical needs and information in case of an emergency.
x. Information relating to disciplinary or grievance investigations and proceedings
involving you (whether or not you were the main subject of those proceedings).
xi. Information relating to your performance and behaviour at work.
xii. Training records.
xiii. Electronic information in relation to your use of IT systems/swipe cards/telephone
xiv. Your images (whether captured on CCTV, by photograph or video).
xv. Any other category of personal data which we may notify you of from time to time.

4. How we define special categories of personal data
a. ‘Special categories of personal data’ are types of personal data consisting of information
i. your racial or ethnic origin;
ii. your political opinions;
iii. your religious or philosophical beliefs;
iv. your trade union membership;
v. your genetic or biometric data;
vi. your health; and
vii. your sexual orientation.
We may hold and use any of these special categories of your personal data in accordance with
the law.

We may also hold and use personal data relating to criminal allegations, offences,
proceedings, and convictions.

5. How we define processing
a. ‘Processing’ means any operation which is performed on personal data such as:
i. collection, recording, organisation, structuring or storing;
ii. adaption or alteration;
iii. retrieval, consultation or use;
iv. disclosure by transmission, dissemination or otherwise making available;
v. alignment or combination; and
vi. restriction, destruction or erasure.

This includes processing personal data which forms part of a filing system and any automated

6. How will we process your personal data?
a. We will process your personal data (including special categories of personal data) in line with
our obligations under the 2018 Act.

b. We will use your personal data:
i. for performing the employment contract (or contract for services) between us;
ii. for complying with any legal obligation; or
iii. if it is necessary for our legitimate interests (or for the legitimate interests of someone
else). However, we can only do this if your interests and rights do not override ours (or
theirs). You have the right to challenge our legitimate interests and request that we stop
this processing. See details of your rights in section 12 below.

We can process your personal data for these purposes without your knowledge or consent.
We will not use your personal data for an unrelated purpose without telling you about it and
the legal basis that we intend to rely on for processing it.

If you choose not to give us certain personal data, we may not be able to carry out some parts
of the contract between us. For example, if we do not have your bank account details, we may
not be able to pay you. It might also prevent us from complying with certain legal obligations
and duties, such as to pay the right amount of tax to HMRC or to make reasonable adjustments
in relation to any disability you may have.

7. Examples of when we might process your personal data
a. We have to process your personal data in various situations during your recruitment,
employment (or engagement) and even following termination of your employment (or

b. For example (and see section 7.6 below for the meaning of the asterisks):
i. to decide whether to employ (or engage) you;
ii. to decide how much to pay you, and the other terms of your contract with us;
iii. to check you have the legal right to work for us;
iv. to carry out the contract between us including, where relevant, its termination;
v. to train you and review your performance*;
vi. to decide whether to promote you;
vii. to decide whether and how to manage your performance, absence, or conduct*;
viii. to carry out a disciplinary or grievance investigation or procedure in relation to you or
someone else;
ix. to determine whether we need to make reasonable adjustments to your workplace or
role because of your disability*;
x. to monitor diversity and equal opportunities*;
xi. to monitor and protect the security (including network security) of the Company, you,
our other staff, customers, and others;
xii. to monitor and protect the health and safety of you, our other staff, customers and
third parties*;
xiii. to pay you and provide pension and other benefits in accordance with the contract
between us*;
xiv. to pay tax and National Insurance;
xv. to provide a reference upon request from another employer;
xvi. to pay trade union subscriptions*;
xvii. to monitor compliance by you, us and others with our policies and our contractual
xviii. to comply with employment law, immigration law, health and safety law, tax law and
other laws which affect us*;
xix. to answer questions from insurers in respect of any insurance policies which relate to
xx. to run our business and plan for the future;
xxi. for the prevention and detection of fraud or other criminal offences;
xxii. to defend the Company in respect of any investigation or litigation and to comply with
any court or tribunal orders for disclosure*; and
xxiii. for any other reason which we may notify you of from time to time.

c. We will only process special categories of your personal data (see above) in certain situations
in accordance with the law. For example, we can do so if we have your explicit consent. If we
ask for your consent to process a special category of personal data, then we will explain the
reasons for our request. You do not need to consent and can withdraw consent later if you
choose by contacting Antony Morton, the Company’s Data Protection Manager.

d. We do not need your consent to process special categories of your personal data when we are
processing it for the following purposes:
i. Where it is necessary for carrying out rights and obligations under employment law.
ii. Where it is necessary to protect your vital interests or those of another person where
you/they are physically or legally incapable of giving consent.
iii. Where you have made the data public.
iv. Where processing is necessary for the establishment, exercise or defence of legal
v. Where processing is necessary for the purposes of occupational health or for the
assessment of your working capacity.

e. The Company may request to process a DBS online check if the employee’s role or work should
require such a check. Permission will be requested directly to the individual and the Company
will process the check on behalf of the individual. If the individual does not wish the check to be
processed, they must inform the Data Protection Manager directly. Any information disclosed will
be treated as confidential data.

f. We might process special categories of your personal data for the purposes in paragraph 7.2
above which have an asterisk beside them. In particular, we will use information in relation
i. your race, ethnic origin, religion, sexual orientation or gender to monitor equal
ii. your sickness absence, health and medical conditions to monitor your absence, assess
your fitness for work, to pay you benefits, to comply with our legal obligations under
employment law including to make reasonable adjustments and to look after your
health and safety; and
iii. your trade union membership to pay any subscriptions and to comply with our legal
obligations in respect of trade union members.

g. We do not take automated decisions about you using your personal data or use profiling in
relation to you.

8. Sharing your personal data
a. Sometimes we might share your personal data with our contractors and agents to carry out
our obligations under our contract with you or for our legitimate interests. For further
information about our Company Privacy policy, you can view on our website here -

Privacy Policy

b. We require those people and companies to keep your personal data confidential and secure
and to protect it in accordance with the law and our policies. They are only permitted to
process your data for the lawful purpose for which it has been shared and in accordance with
our instructions.

c. We work with an external their party Accountant who processes all of our Company payroll.
They are required under contract to keep all information shared with them by us safe and they
do not share any of the data we provide them with to any other parties.

d. We do not send your personal data outside the European Economic Area. If this changes, we
will tell you. We will also explain the protections that are in place to protect the security of
your data.

9. How should you process personal data for the Company?
a. Everyone who works for, or on behalf of, the Company has some responsibility for ensuring
data is collected, stored and handled appropriately, in line with this and other relevant

b. The Company’s Data Protection Officer is responsible for reviewing this policy and updating
the Board of Directors on the Company’s data protection responsibilities and any risks in
relation to the processing of data. You should direct any questions in relation to this policy or
data protection to this person.

c. You should only access personal data covered by this policy if you need it for the work you do
for, or on behalf of the Company and only if you are authorised to do so. You should only use
the data for the specified lawful purpose for which it was obtained.

d. You should not share personal data informally.

e. You should keep personal data secure and not share it with unauthorised people.

f. You should regularly review and update personal data which you have to deal with for work.
This includes telling us if your own contact details change.

g. You should not make unnecessary copies of personal data and should keep and dispose of any
copies securely.

h. You should use strong passwords.

i. You should lock your computer screens when not at your desk.

j. Any personal data which is shared to any authorised external contacts is sent in a safe and
password protected environment.

k. Consider anonymising data or using separate keys/codes so that the data subject cannot be

l. Do not save personal data to your own personal computers or other devices.

m. Personal data should never be transferred outside the European Economic Area except in
compliance with the law and authorisation of the Data Protection Officer.

n. You should lock drawers and filing cabinets. Do not leave paper that contains personal data
lying about.

o. You should not take personal data away from Company’s premises without authorisation from
your line manager or our Data Protection Officer.

p. Personal data should be shredded and disposed of securely when you have finished with it.

q. You should ask for help from our Data Protection Officer if you are unsure about data
protection or if you notice any areas of data protection or security we can improve upon.

r. Any deliberate or negligent breach of this policy by you may result in disciplinary action being
taken against you under our Disciplinary Policy.

s. It is a criminal offence to conceal or destroy personal data which is part of a subject access
request (see below). This conduct would also amount to gross misconduct under our
Disciplinary Policy and you could be dismissed.

10. How to deal with data breaches
a. If this policy is followed, we should not have any data breaches. But if a breach of personal
data occurs (whether in respect of you or someone else) then we must take notes and keep
evidence of that breach. If the breach is likely to result in a risk to the rights and freedoms of
individuals then we must also notify the Information Commissioner’s Office within 72 hours,
where feasible.

b. If you are aware of a data breach you must contact the Data Protection Officer immediately
and keep any evidence, you have in relation to the breach.

11. Subject access requests
a. Data subjects can make a ‘subject access request’ (‘SAR’) to find out what information we hold
about them. This request must be made in writing. If you receive a SAR, you should forward it
immediately to the Data Protection Officer who will coordinate a response.

b. To make a SAR in relation to your own personal data, you should write to the Data Protection
Officer. We must respond within one month unless the request is complex or numerous in
which case the period in which we must respond can be extended by up to two months.

c. There is no fee for making a SAR. However, if your request is manifestly unfounded or
excessive, we may charge a reasonable administrative fee or refuse to respond to your
request. We normally work on the basis that any request which will take more than a day to
deal with is likely to be manifestly excessive, and in those circumstances we believe a
reasonable charge is one working day’s salary for you.

12. Your data subject rights
a. You have the right to information about what personal data we process, how and on what
basis as set out in this policy.

b. You have the right to access your own personal data by way of a SAR (see above).

c. You can correct any inaccuracies in your personal data by contacting the Data Protection

d. You have the right to request that we erase your personal data where we were not entitled
under law to process it, or where it is no longer necessary to process the data for the purpose
for which it was collected. You can request erasure by contacting the Data Protection Officer.

e. During the process of requesting that your personal data is corrected or erased, or while you
are contesting the lawfulness of our processing, you can ask for the data to be used in a
restricted way only. To do this, contact the Data Protection Officer.

f. You have the right to object to data processing where we are relying on a legitimate interest
to do so and you think that your rights and interests outweigh our own and you wish us to

g. You have the right to object if we process your personal data for the purposes of direct

h. You have the right to receive a copy of your personal data and, with some exceptions, to
transfer your personal data to another data controller. We will not charge for this and will in
most cases aim to do this within one month.

i. With some exceptions, you have the right not to be subjected to automated decision making.

j. You have the right to be notified of a data security breach concerning your personal data
where that breach is likely to result in a high risk of adversely affecting your rights and

k. In most situations we will not rely on your consent as a lawful ground to process your data.
If we do request your consent to the processing of your personal data for a specific purpose,
you have the right not to consent or to withdraw your consent later. To withdraw your
consent, you should contact the Data Protection Officer.

l. You have the right to complain to the Information Commissioner. You can do this by
contacting the Information Commissioner’s Office directly. Full contact details including a
helpline number can be found on the Information Commissioner’s Office website
( This website has more information on your rights and our obligations.