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Our People

Collection
We will collect names, addresses, contact details, education and employment history, identity and other background checks (which may include appropriate criminal and financial checks and confirmation of the right to work in the UK), marital status and information on next of kin and dependents, financial information (such as bank details and NI numbers), date of birth, gender, a copy of your passport and driving licence, performance information and compensation history, recruitment information (including references), salary, benefits, pension and annual leave information, disciplinary and grievance information, photographs, information about your use of our information and communications systems or other information obtained through electronic means. 

We may collect and use special categories of personal information as required in the carrying out of obligations and exercising specific rights of us or the data subject in the field of employment. This may include information relating to matters such as health, racial origin, religious belief and offences or alleged offences.

Personal information may be collected from you during the selection process (for example via your application form and CV) and during your employment (including holiday forms, expense claims, performance reviews, any disciplinary or grievance processes), or from third parties, including referees, health service providers and background check providers.   

Use
Personal information of our people will be used for HR administration and management, both in respect of the selection of people to work for us (including suitability, eligibility and/or fitness to work), and those who do work for us, to include learning and development, disciplinary and security (of people, offices and data) requirements, providing and liaising with benefits providers, business management and planning (including accounting and auditing), paying you and dealing with tax and NI deductions, assessing and deciding on salary reviews and compensation, conducting performance reviews and managing performance, dealing with legal disputes involving you or others, preventing fraud, monitoring your use of our information and communications systems, ensuring compliance with our policies, and equal opportunities monitoring. 

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:

  • In performance of a contract with you; and/or
  • compliance with a legal obligation; and/or
  • vital interests of the data subject; and/or
  • 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 less common:

  • where we need to protect your interests (or someone else’s interests);
  • where it is needed in the public interest or for official purposes.

In respect of all disclosures of personal information, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal information is appropriately protected.   

In respect of special categories of personal information, we may process this in the following circumstances:

  • in limited circumstances with your explicit written consent; and/or
  • where we need to carry out our legal obligations and in line with our policies; and/or
  • 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 policies; and/or
  • 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 (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 our people (or former people) in the course of our legitimate business activities with the appropriate safeguards. 

The special categories of personal information may be used in the following ways: 

  • in relation to leaves of absence, to comply with employment and other laws;
  • in relation to 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 monitor, manage and administer benefits and absences;
  • in relation to your race, national or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Disclosure
Personal information may be transferred to service providers who support the operation of our business (such as payroll service providers), to other third parties reasonably necessary in the conduct of our business (including insurers, professional advisors, regulators). These third parties may be acting as processor, or controller of personal information in their own right. Personal information may also be shared with our clients in offering or in the provision of legal services. 

In respect of all disclosures of personal information, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal information is appropriately protected.   

Retention Period
We will keep personal information only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. We will normally keep personal information of applicants who we do not employ for six months after we receive it. 

We will keep personal information of employees throughout your employment and normally for a minimum of six years after your employment ends.