Privacy Notice - RWP Staff
Privacy Notice – How we use employee information
This statement explains how RWP Training Limited handles and uses personal data we collect about staff. Where in the statement we refer to ‘we’ or ‘our’ we are referring to RWP Training Limited, and where we refer to ‘you’ or ‘your’ we are referring to our staff. We are registered with the Information Commissioner’s Office (ICO) with registration number Z597115X
We are committed to protecting your personal information and to being transparent about what information we hold. RWP Training understands its obligations to you to help you understand how and why we process your personal data. This notice tells you about these uses and should be read in conjunction with the RWP Training data protection policy.
Our data protection policy and procedures are governed by the Data Protection Act 1998 and, from 25th May 2018, the EU General Data Protection Regulation.
Why we hold your personal data
We are required to hold your personal data for various legal and practical purposes, without which we would be unable to employ you.
Holding your personal data enables us to meet various administrative and legal obligations (eg for tax purposes).
Lawful basis for processing personal data
The lawful basis for processing the personal data of staff is to fulfil a contract of employment with you. There is a contractual requirement for you to provide much of the information detailed. Without this we will be unable to fulfil our obligations which could result in the contract terminating.
RWP Training may also store some of your personal data in accordance with other privacy notices, for example, if you have been a student or apprentice of RWP Training.
Personal data held by RWP Training
Much of the information we hold will have been provided by you when applying for your job, but some may come from internal sources, such as your manager, or in some cases external sources, such as referees. The personal data we may hold about you is as follows:
Your name; contact details; date of birth; N.I. number; tax code; bank details; attendance and hours of work; P45 information from previous employer; your signature; photographs of you; details of your education, qualification and publications; emergency contact details (name and contact number).
Your application form and CV; details of your career; interview records; references; your contract of employment; correspondence to you about you; absences and reason; performance reviews; disciplinary, grievance and capability procedures; accidents at work; training provided; copy of driving licence; copy of car business insurance.
In addition, we monitor computer and telephone use (including mobile phones if provided by the business), as detailed in our Terms and Condition of Employment and our Internet and E-mail Policy.
Sensitive personal data held by RWP Training
The information we hold is that which you provided when applying for your job, supplemented by information generated during your induction period, and through the course of your employment.
Your gender; ethnic origin; disabilities; criminal convictions; medical information.
How your personal data is used by RWP Training
Your data is used by us for a number of purposes:
· Payroll processing and payment of salaries and pension contributions
· Criminal record bureau checks
· Awarding body accreditation
· Management Information System (Maytas and E-track)
· Issue of petrol cards
· Internal display boards and notices
· Internal reporting and record keeping
· Informing the development of recruitment and retention policies
· Publications and promotion of events
· Marketing, including images, online, in print and on social media (with your consent)
· Communicating with you
· Complying with our legal and regulatory obligations
· Providing references for future employer
Communications to you may be sent by post, telephone or a work e-mail address. Your personal mobile number or personal e-mail address will only be used if you have given consent.
Sharing your data with others
· Personal data may be shared with other members of staff, who legitimately need the information to carry out their normal duties to support your time with us.
· Sensitive personal data will only be shared with colleagues with your explicit consent.
· Sensitive data may be shared without your consent where it is necessary to protect your vital interests or the vital interest of another person; or for certain other reasons such as disclosures to the police for prevention or detection of crime, or to meet statutory obligations relating to equality monitoring.
Sharing your data with third parties
RWP training may share certain personal data to third parties as follows:
· Relevant data will be shared with our payroll providers and may be shared with our accountants
· Relevant data will be shared with our pension provider
· Relevant data may be shared with the Education and Skills Funding Agency
· Relevant data may be shared with Awarding Bodies depending on the requirements of your job
· Relevant data may be shared with the Criminal Records Bureau
· Relevant data may be shared with your next of kin but only with your consent or in an emergency
· Data may be shared with reputable ‘data processors’ for the purpose of sending communications (eg mail chimp)
· With your permission we may share information about you for publicity and marketing purposes online, in print and on social media
RWP Training does not share data with any other third party, except as allowed for in other privacy notices or required by law.
How long data is kept
We will keep your personal data only as long as is necessary for the purpose(s) for which it was collected. Data will be securely destroyed when no longer required.
Income tax and NI returns, income tax records and correspondence with HMRC
3 years after the end of the financial year to which they relate
Wages/salary records (including bonuses, overtime, expenses
6 years plus current year (7 years total)
Personnel files and training records (including redundancy records)
6 years after employment ceases
National minimum wage records
3 years after the end of the pay reference period following the one that the records cover
Statutory Maternity/Adoption/Paternity leave/pay records, calculations, certificates (Mat B1s) or other medical evidence
3 years after the end of the tax year in which the maternity period ends
Records relating to working time
2 years from the date on which they were made
3 years after the end of the tax year to which the records relate
6 months after the employer has appointed
Accident books, accident records/reports
3 years from the date of the last entry (or, if the accident involves a child/ young adult, then until that person reaches the age of 21).
How your data is kept secure
Any hard copy data is kept in your personnel file which is kept in a locked filing cabinet, which is only accessible to the board members. Any data which may be held digitally is password protected and only accessible to authorised personnel.
You have the following rights
Under the General Data Protection Regulations (GDPR) and the Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability.
We will endeavour to comply with all such requests within one month of the request (unless the request is unfounded or excessive).
If you have provided consent for the processing of your data you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
We reserve the right to judge what information we must continue to hold to be able to fulfil our contract with you.
You have the right to lodge a complaint with the Information Commissioner’s Office at http://ico.org.uk/concerns
If you require any further information or wish to ask us not to process your personal data for particular purposes or to erase your data please contact our Managing Director, Karen Polyblank, email@example.com. Where you have specific requests relating to how we manage your data, we will endeavour to resolve these, but please note that there may be circumstances where we cannot comply with specific requests.