The organisation is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the organisation's commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to the personal data of job applicants, employees, workers, and apprentices and former employees, referred to as HR-related personal data. This policy does not apply to the personal data of clients or other personal data processed for business purposes.
The organisation has appointed the Group HR Director as the person with responsibility for Data Protection compliance within the organisation. She can be contacted at St Vincent House, Normanby Road, Scunthorpe, DN15 8QT. Questions about this policy, or requests for further information, should be directed to her.
"Personal data" is any information that relates to a living individual who can be identified from that information.
“Processing” is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.
The organisation processes HR-related personal data in accordance with the following data protection principles:
The organisation tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where the organisation relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.
The organisation will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Personal data gathered during the employment, worker relationship, or apprenticeship is held in the individual's personnel file (in hard copy and electronic format), and on HR systems. The periods for which the organisation holds HR-related personal data are contained in its privacy notices to individuals.
The organisation keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell him/her:
The organisation will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.
If the individual wants additional copies, the organisation will charge a fee, which will be based on the administrative cost to the organisation of providing the additional copies.
To make a subject access request, the individual should use the organisation's form for making a subject access request. In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.
The organisation will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the organisation processes large amounts of the individual's data, it may respond within three months of the date the request is received.
The organisation will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, the organisation is not obliged to comply with it. Alternatively, the organisation can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the organisation has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify him/her that this is the case and whether or not it will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require the organisation to:
To ask the organisation to take any of these steps, the individual should send the request to firstname.lastname@example.org. You can make a subject access request by completing the organisation's form for making a subject access request.
The organisation takes the security of HR-related personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. [Provide more detail of internal policies and controls, e.g. systems restrictions and data security policy.]
Where the organisation engages third parties to process personal data on its behalf, such parties do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes, for example if an individual move to a new house or changes his/her bank details.
Individuals may have access to the personal data of other in the course of their employment, contract, or apprenticeship. Where this is the case, the organisation relies on individuals to help meet its data protection obligations to staff.
Individuals who have access to personal data are required:
Further details about the organisation's security procedures can be found in its IT Security Policy.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
The organisation will ensure that all individuals are aware of their data protection responsibilities as part of the induction process and at regular intervals thereafter.
Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional support to help them understand their duties and how to comply with them.