1.   Purpose

Steatite Limited (“the Company”) 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 UK General Data Protection Regulation (UK GDPR).

It applies to all employees, workers and contractors.

2.   Responsibilities

Individuals are responsible for helping the Company keep their personal data up to date. They should let the Company know if data provided to the Company changes, for example if they move house or change bank details. It is the individual’s responsibility to ensure that the data is correct at the time it is collected and at regular intervals after. 

Steatite Limited is a “controller”. This means that we are responsible for deciding how we hold and use personal information about you. The Company is committed to being transparent about how it collects and uses that data to meet its data protection obligations.

3.   Principles

The Company recognises the following principles and follows this in its management of data:

· Data processing will be fair, lawful and transparent

· Data will be collected and processed for specified, explicit and legitimate purposes

· Data collected will be adequate, relevant and limited to what is necessary to meet the identified purposes

· Data will be accurate and kept up to date

·  Data will only be kept for as long as it is required to meet purpose and/or to meet legal, regulatory or best practice retention

· Data will be processed and stored in a secure manner which guards against unauthorised or unlawful processing and against accidental loss, destruction or damage

4.   Information collected and held

The Company collects and processes a range of information about you, for example:

·       Your title, name, address and contact details, including email address and telephone number

·       Your date of birth

·       Gender

·       Ethnic origin

·       Nationality

·       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 and, if different, the date of your continuous employment

·       Leaving date and your reason for leaving

·       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 an application process.

· Employment records, including job titles, work history, working hours and patterns, training records, professional memberships, compensation history, performance information, disciplinary and grievance information.

·  CCTV footage and other information obtained through electronic means such as swipe card or door fob records

· Information about medical or health conditions, including whether or not you have a disability which the Company needs to make reasonable adjustments for

· Where you leave employment and under any share plan operated by the Company (or any group company) the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision

· Details of any absences from work, including annual leave, sickness absence and statutory leave such as maternity, paternity, parental, emergency dependents leave and bereavement leave

· Where you leave employment and the reason for leaving is related to your health

· Details of trade union membership

· Equal opportunities monitoring information, including ethnic origin, sexual orientation, health and religion or belief

· Information about your use of our information and communication systems

· Photographs

·  Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied

5.   How information is collected

The Company collects personal information in a variety of ways. For example:

·      Through the application process from application forms and CVs

·      Obtained from your passport or other identity documents such as a driving licence

·      From forms completed by you at the start or during your employment, such as benefit nomination forms

·      From correspondence with you

·      Through meetings and assessments

In some case the Company may collect personal information about you from third parties, such as references provided by former employers and information from criminal records checks permitted by law. The Company may collect additional personal information in the course of job-related activities during the period you work for us

6.   How information is used

The Company will only use your personal information when the law allows us to. Predominantly we will use your information in the following circumstances:

·       Where the Company has entered into an employment contract with you and need to meet our obligations under that

·       Where the Company need to comply with a legal obligation, for example deducting tax, checking right to work or carrying out criminal records check required for some roles

·       Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests

·       To maintain accurate and up-to-date employment records and contact details, including details of who to contact in the event of an emergency

·       Maintain records of employee contractual and statutory rights

·       Operate and keep a record of disciplinary and grievance processes to ensure acceptable conduct within the workplace

·       Operate and keep a record of employee performance and related processes to plan for career development and for succession planning and workforce management purposes

·       Operate and keep a record of absence and absence management procedures to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled

·       Operate and keep a record of other types of leave, including maternity, paternity, adoption, parental and shared parental leave, to allow effective workforce management, to ensure the Company complies with duties in relation to leave entitlement and to ensure that employees are receiving the pay and other benefits to which they are entitled

·       Ensure effective general HR and business administration

·       Provide references on request for current or former employees

·       Respond to and defend legal claims

·       Maintain and promote equality in the workplace

7.   Who has access to data

Your information will be shared internally with members of HR and payroll, your line manager and the managers in the business area in which you work.

The Company shares your data with third parties in order to obtain pre-employment references from other employers and obtain any necessary criminal record checks.

The Company may also share your data with the provider of the HR information system in order to fix any errors with the system. A data sharing agreement is signed by the HR information system provider to ensure that they only use the system for purposes of fixing the issue and that the system access is withdrawn once the issue is fixed. The data is not kept by them and is transferred through a secure site. In all cases where this happens the data will be subject to a confidentiality agreement.

The Company will also share your data with third parties that process data on its behalf in connection with payroll, the provision of pensions and benefits and the provision of occupational health services.

The Company will not transfer your data to countries outside of the United Kingdom unless the Company is satisfied that there is an adequate level of protection for the data in place.

The Company may share your data with other third parties, for example in the situation of a possible sale or restructuring of the business. In this situation we will, in so far as possible, share anonymised data with other parties before the transaction completes. Once the transaction is completed, the Company will share your personal data with other parties if and to the extent required under the terms of the transaction.

8.   Data security

The Company takes the security of your data seriously. The Company has internal policies and controls in place to try and ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed other than by employees in the performance of their duties.

Access to data is protected by individual profiles for data use depending upon the need of the individual and is secured through password entry. The password entry systems are compliant with the Company’s security processes.

Where the Company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. Third parties will also be required to enter into an appropriate data sharing agreement. 

9.   Data retention

The Company 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 data are available in the Data Retention policy.

In some circumstance the Company may anonymise your personal information so that it can be no longer associated with you. In this case, we may use such information without further notice to you.

Once you are no longer an employee, contractor or worker of the Company, we will retain and securely destroy your personal information in accordance with the Company’s Data Retention policy.

10.Your rights

As a data subject, you have several rights. These are:

· The right to be informed about what data is collected and how it is used (this Notice helps to comply with this right)

· The right to request access to your data and other information held about you

· The right to have any mistakes or inaccuracies in your data put right

· The right to request the deletion or removal of data where there is no compelling reason for its continued use

· The right to restrict the processing of data where it is inaccurate, or consideration of the lawful basis or legitimate interest is on going

· The right to portability (allowing you to get and reuse your data for different services)

· The right to object to processing in certain circumstances (such as direct marketing, profiling or scientific research)

· The right to be informed about and object to data being used for some automated decision making, such as profiling

If you would like to exercise any of these rights, please contact the HR department in writing. If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner's Office (ICO) via their website www.ico.org.uk or via phone on 0303 123 1113.

11.Failing to provide information

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

12. Change of purpose

We will only use your personal information for the purpose for which it was collected, unless the Company reasonably consider that we need to use it for another reason that is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose we will notify you and will explain the legal basis which allows us to do so

The Company may process your personal information without your knowledge or consent in compliance with our legal obligations.

13. Automated decision making

The Company do not base employment decisions on automated decision making.

14.Changes to the notice

The Company reserve the right to update this privacy notice at any time and 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.