Employee Privacy Notice

INTRODUCTION

Zuboid Limited, (“Zuboid Courier”, “we”, “us”, “our”) is committed to protecting the privacy and security of your Personal Data. This Privacy Policy describes how we through our programmes and projects collect and use Personal Data about our employees (collectively referred to “you” or “your”).

This we do in accordance with the UK’s Data Protection Act (“DPA”), the General Data Protection Regulation (“GDPR”).

SCOPE

The policy covers both personal and special category personal data held in relation to you. This policy applies equally to personal data held in print and digital form.

All employees and others processing personal data on our behalf must read it, and a failure to comply may result in disciplinary action. All managerial and executive staff are responsible for ensuring that their subordinated staff is complying with this policy and should implement appropriate practices, processes, controls, and training accordingly.

We may update this policy at any time, but if we do so, we will provide you with an updated copy as soon as reasonably practical.

It is important that Employees read and retain this Privacy Policy, together with any other Privacy Policy we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are aware of how and why we are using such information and what your rights are under the DPA and the GDPR.

THE SUPERVISORY AUTHORITY

Under consideration of the data protection requirements deriving from the DPA and the GDPR, we recognise that you have the right to make a complaint at any time with a supervisory authority responsible for data protection. The supervisory authority in the UK is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or any other supervisory authority.

THE DATA CONTROLLER

Zuboid Courier is a “data controller” which means that we are responsible for deciding how we hold and use Personal Data about you.

DATA PROTECTION PRINCIPLES

Zuboid Courier is responsible for, and must be able to demonstrate compliance with the data protection principles set out and all personal data must be:

  1. Used lawfully, fairly, and in a transparent way;
  2. Collected only for valid purposes that we have clearly explained to you;
  3. Used in any way that is incompatible with the purposes it was collected for;
  4. Relevant to the purposes we have told you about and limited only to those purposes;
  5. Accurate and kept up to date;
  6. Kept only as long as necessary for the purposes we have told you about; and
  7. Kept securely.

THE INFORMATION WE HOLD ABOUT YOU

Personal data 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 also “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation.

We will collect, store, and use the following categories of Personal Data:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
  • Date of birth;
  • Gender;
  • Marital status and dependents;
  • Next of kin and emergency contact information;
  • Bank account details, payroll records, and tax status information;
  • Salary, annual leave, pension, and benefits information;
  • Start date and, if different, the date of an Employee’s continuous employment;
  • Location of employment or workplace;
  • Copy of driving license (where applicable);
  • 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, holidays, training records, and professional memberships);
  • Personnel files and training records including performance information, disciplinary and grievance information, and working time records;
  • Information about your use of our records, information, and communications systems; and
  • Records of any reportable death, injury, disease, or dangerous

We may also collect, store, and use the following “special categories” of more sensitive Personal Data:

  • Information about an Employee’s race or
  • Information about an Employee’s health, including any medical condition, accident, health, and sickness records, including:
    • where an Employee leaves employment and under any share plan operated by a 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 (other than holidays) from work, including time on statutory parental leave and sick leave; and
    • where an Employee leaves employment and the reason for leaving is related to their health, information about that condition is needed for pensions and permanent health insurance purposes.

HOW DO WE COLLECT PERSONAL DATA?

We collect Personal Data about Employees 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.

We will collect additional Personal Data in the course of job-related activities throughout the period of when an Employee works for us.

HOW DO WE PROCESS THE INFORMATION COLLECTED ABOUT YOU?

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  1. Where we need to perform the contract we have entered into with
  2. Where we need to comply with a legal
  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 Data 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 PROCESS YOUR PERSONAL DATA

We need all the categories of information in the list above primarily to allow us to perform our contracts with Employees and to enable us to comply with legal obligations. The situations in which we will process Employee Personal Data are listed below.

  • Making a decision about an Employee’s recruitment or appointment;
  • Paying an Employee and, if an Employee is an Employee or deemed Employee for tax purposes, deducting tax and social insurance contributions;
  • Providing any Employee benefits to Employees;
  • Enrolling you in a pension arrangement;
  • Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider, and any other provider of employee benefits;
  • Administering the contract, we have entered into with an Employee;
  • Conducting performance and/or salary reviews, managing performance, and determining performance requirements;
  • Assessing qualifications for a particular job or task, including decisions about promotions;
  • Gathering evidence for possible grievance or disciplinary hearings;
  • Making decisions about an Employee’s continued employment, engagement;
  • Making arrangements for the termination of our working relationship;
  • Education, training, and development requirements;
  • Dealing with legal disputes involving Employees, including accidents at work;
  • Ascertaining an Employee’s 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; and
  • Equal opportunities

Some of the above grounds for processing will overlap, and there may be several grounds which justify our use of an Employee’s Personal Data.

IF EMPLOYEES FAIL TO PROVIDE PERSONAL DATA

If Employees fail to provide certain information when requested, we may not be able to perform the respective contracts we have entered into with Employees or we may be prevented from complying with our respective legal obligations to Employees.

CHANGE OF PURPOSE OF PROCESSING

We will only use your Personal Data 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 Data for an unrelated purpose, we will notify the Employee, as is appropriate in the circumstances, and we will explain the legal basis which allows us to do so.

Please note that we may process an Employee’s Personal Data without their respective knowledge or consent, as relevant to the circumstances, in compliance with the above rules, where this is required or permitted by law.

HOW DO WE PROCESS SENSITIVE PERSONAL DATA?

”Special categories” of particularly sensitive Personal Data require higher levels of protection. We need to have further justification for collecting, storing, and using this type of Personal Data. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of Personal Data in the following circumstances:

  • In limited circumstances, with Employee explicit written consent;
  • Where we need to carry out our legal obligations or exercise rights in connection with Employee employment; and
  • Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims, where it is needed to protect an Employees interests (or someone else’s interests) and the Employee is not capable of giving consent, or where the Employee has already made the information public.

OUR OBLIGATIONS AS AN EMPLOYER

We will use particularly sensitive Personal Data of Employees 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 the physical or mental health of an Employee, or their disability status, to ensure Employee health and safety in the workplace and to assess the fitness of Employees to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence, and to administer benefits including statutory maternity pay, statutory sick pay, pensions, and permanent health insurance; and
  • We will use information about an Employee’s race or national or ethnic origin, religious, philosophical, or moral beliefs, or an Employee’s sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

DO WE NEED EMPLOYEE CONSENT?

We do not need the consent of Employees if we use special categories of Personal Data 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 Employees for their written consent to allow us to process certain particularly sensitive data. If we do so, we will provide Employees with full details of the information that we would like and the reason we need it, so that Employees can carefully consider whether they wish to consent. Employees should be aware that it is not a condition of their contract with Zuboid Courier that they agree to any request for consent from us.

INFORMATION ABOUT CRIMINAL CONVICTIONS

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 the interests of you (or someone else’s interests) and you are not capable of giving your consent, or where an Employee has already made the information public.

AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses Personal Data to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  • Where we have notified Employees of the decision and given the Employee 21 days to request a reconsideration;
  • Where it is necessary to perform the contract with an Employee and appropriate measures are in place to safeguard the Employee’s rights as is appropriate;
  • In limited circumstances, with explicit written consent from the Employee and where appropriate measures are in place to safeguard Employee rights;
  • If we make an automated decision on the basis of any particularly sensitive Personal Data, we must have either explicit written consent from an Employee or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard an Employee; and
  • 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 the Employee.

WHEN DO WE SHARE PERSONAL DATA?

We will share Your Personal Data 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.

HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data 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.

HOW LONG WILL YOU KEEP MY INFORMATION FOR?

We will only retain Your Personal Data 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 our retention policy which is available from the manager.

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 Data 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, we will retain and securely destroy your Personal Data in accordance with applicable laws and regulations.

ACCURACY

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your working relationship with us.

YOUR RIGHTS IN CONNECTION WITH PERSONAL DATA

Under the DPA and the GDPR, you can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;The right to data portability;

DATA SUBJECT ACCESS REQUESTS

If you want to review, verify, correct, or request erasure of your Personal Data, object to the processing of your personal data, or request that we transfer a copy of your Personal Data to another party, please contact the manager in writing. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). 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 Data 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 Data 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 us. 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.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data. If you have any questions about this Privacy Policy, please contact us.

ACCESS TO THIS POLICY

On commencing employment with Zuboid Courier every new employee will be given a copy of this policy and an opportunity to discuss it.