Privacy

• The organisation processes personal data lawfully, fairly and in a transparent manner.
• The organisation collects personal data only for specified, explicit and legitimate purposes.
• The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
• The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
• The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
• 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 processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.
• The organisation will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during employment is held in the individual’s personnel file in hard copy or electronic format, or both, and on HR systems. The periods for which the organisation holds personal data are specified in its privacy notices to individuals. The organisation keeps a register of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

• whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
• to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
• for how long his/her personal data is stored;
• his/her rights to rectification or erasure of data, or to restrict or object to processing;
• his/her right to complain to the Information Commissioner if he/she thinks the organisationhas failed to comply with his/her data protection rights; and whether or not the organisation carries out automated decision-making and the logicinvolved in any such decision-making.

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. To make a subject access request should send the request to the organisations HR Manager. 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.

• to access only data that they have authority to access and only for authorised purposes;
• not to disclose data except to individuals (whether inside or outside the organisation) whohave appropriate authorisation;
• to keep data secure (for example by complying with rules on access to premises, computeraccess, including password protection, and secure file storage and destruction);
• not to remove personal data, or devices containing or that can be used to access personaldata, from the organisation’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
• not to store personal data on local drives or on personal devices that are used for workpurposes; and
• to report data breaches of which they become aware to the HR Manager immediately.