ABOUT THIS NOTICE

This Privacy Notice explains how Work.Life Limited (or “the Company”) collects and uses personal information about its employees, its officers, directors, consultants, contractors, interns/trainees, homeworkers, casual staff, agency staff and volunteers – collectively referred to in this notice as “staff” – during their working relationship with us and afterwards. This is important information, which applies to all staff, who should read it carefully.

We will review how we use your personal information from time to time, and notify you of any significant changes, particularly where we plan to collect and/or use your personal information in ways not explained in this notice.  We will also review and update this notice from time to time.  This notice is not a contractual document.

In this notice, we refer to “processing” and “personal data”.   “Personal data” means information which identifies you and relates to you as an individual.  “Processing” effectively means anything that we do with your personal data, including collecting, recording, storing, destroying, sending to third parties, and amending.

This notice also refers to “special categories” of personal data.  These are special categories of more sensitive personal data, which require a higher level of protection, for example information about a person’s health or sexual orientation.

Work.Life Limited of 66 Prescot Street, London, E1 8NN is the relevant data controller in relation to the personal information we hold in relation to the employment or engagement or our staff.

If you have any questions or concerns about this notice, or how we use personal information, please contact Elliot Gold, our Data Protection Officer on eg@work.life.

 

DATA PROTECTION PRINCIPLES

We will comply with data protection law.  This says that the personal data must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with these purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Not kept longer than necessary for the purposes we have told you about.

 

WHAT PERSONAL DATA DO WE PROCESS?

On a day to day basis, we are likely to collect the categories of personal data which are listed below.  It may be that we process other categories of information.  We will let you know about any significant additions to this list.

• Personal contact details such as name, title, addresses, personal landline and mobile telephone numbers and personal email addresses.
• Business contact information, including your work email address, work landline number, and work mobile telephone number.
• Recruitment information, including references and other information included in a CV or cover letter as part of the application process, background checks.
• Right to work information, including copies of documents (e.g. passport, driving licence, utility bills).
• Your job title.
• Records of outside business interests.
• Date of birth.
• Marital status and dependents.
• Details of registered childcare minder.
• Next of kin and emergency contact information.
• National Insurance number and other social security details.
• Bank account details, payroll records and tax status information.
• Current and previous terms and conditions of employment or engagement with us (including where you have transferred from another employer).
• Offer letters.
• Salary, annual leave, pension and benefits information, including name, date of birth and relationship of any named beneficiaries (including spouses and children).
• Records of holiday and other absences, including maternity, paternity, adoption, parental and compassionate, and sabbatical leave.
• Flexible working applications.
• Start date and, if different, the date of your continuous employment.
• Leaving date and your reason for leaving and notes from any exit interviews.
• Location of employment or workplace.
• Working time opt out agreement.
• Employment records (including job titles, work history, working hours, holidays, and training records).
• Details of professional memberships.
• Regulatory registration.
• Compensation history.
• Performance information and records, including appraisals, performance reviews and ratings, targets, objectives, performance improvement plans, records of career development, records of performance improvement meetings and related correspondence) and warnings.
• Disciplinary information, including notes of meetings, investigation notes and reports, records of warnings and correspondence.
• Grievance information, including notes of meetings, investigation notes and reports, records of warnings and correspondence.
• CCTV footage/recordings made in access and communal areas.
• Information gathered though our monitoring and/or recording of emails, IT systems, telephone systems, audio conferencing.
• Personal data that you have voluntarily provided during your use of our communication systems.
• Records of access to work premises.
• Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are provided.

 

WHAT SPECIAL CATEGORIES OF PERSONAL DATA DO WE PROCESS?

• Information about your health, including any medical condition, disability, health and sickness records, including;
  • Details of any absences (other than holidays) from work including time on maternity leave and sick leave;
  • Details of any discussions/correspondence about your health or sickness absences;
  • Where you leave employment, and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

 

WHAT WILL WE USE YOUR PERSONAL DATA FOR AND HOW WILL WE PROCESS IT?

We will only use your personal data when the law allows us to do so.  Generally, this will be:

1. Where we need to use it to perform our obligations under your employment or engagement contract with us.
2. Where we need to comply with a legal obligation.
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.  

Situations where we will use your personal data include those listed below.  It’s possible that we may process your personal data in other situations, where the law allows us to do so.  If we have anything significant to add to this list, we will let you know.

• Making decisions about your recruitment or employment, and the terms on which you work for us;
• Paying your compensation, administering any benefits (including pensions and any share plans);
• Day to day management of tasks and responsibilities;
• Managing performance, including appraisals;
• Disciplinary and grievance procedures, including investigations;
• Complying with legal requirements, including reporting to the local tax authority and checking you are legally entitled to work in the UK;
• Administering our contract with you;
• Business management and planning, including accounting and auditing;
• Publishing your articles, blogs, pictures etc on social media;
• Making decisions about salary reviews and other compensation;
• Considering promotions and alternative roles;
• Education, training and development requirements;
• Making decisions about continued employment or engagement;
• Making arrangements for the termination of your employment or engagement;
• Dealing with legal disputes involving you or other members of staff;
• Complying with health and safety obligations;
• Preventing fraud;
• Monitoring your use of our information and communication systems;
• To protect our confidential and proprietary information, our intellectual property, and that of our customers/clients/investors/suppliers.

 

WHAT WILL WE USE SPECIAL CATEGORIES OF PERSONAL DATA FOR, AND HOW WILL WE PROCESS IT?

Special categories of personal data require higher levels of protection.  We will always treat special categories of personal data as confidential, and we will only share it where we have a specific and legitimate need to do so.   We have also implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration or disclosure.

We may process special categories of personal data in the following circumstances:

1. In limited circumstances, with your explicit written consent. If we do this, we will give you full details of the information we wish to process, and the reason for this.  It will not be a condition of your employment or engagement that you give your consent.
2. Where we need to carry out our legal obligations or exercise rights in connection with employment.
3. Where it is needed in the public interest, for example, for equal opportunities monitoring.

We will only process special categories of personal data in the following ways:

1. Information about Health

We may process information about your physical or mental health in compliance with our obligations in connection with your employment or engagement.   This may be so that we can:

• Administer sick pay;
• Comply with our obligations in relation to members of staff who are pregnant;
• Facilitate administration of benefits;
• Facilitate a return to work;
• Adapt our work environment, premises or working practices in connection with your health;
• Comply with our obligations towards employees who are or may be disabled;
• Comply with health and safety obligations;
• Maintain a sickness absence record;

 

WHEN WILL WE SHARE YOUR PERSONAL DATA?

We will share staff personal data where it is required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

The third parties with whom we may share your personal data may include:

• payroll providers;
• pension administrators;
• benefits providers, brokers and administrators;
• IT service providers;
• Professional advisors, including tax advisors, legal advisors, external HR providers;
• Occupational health providers;
• HMRC and/or any other applicable government body;
• HR platform service providers.

We will share personal data relating to your participation in any share plans operated by us with third party administrators, nominees, registrars and trustees for the purposes of administering the share plans.

All our third party service providers and other entities in the group are required to take appropriate security measures to protect your personal information 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 WE KEEP YOUR PERSONAL DATA?

We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.   To decide on 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.   We may sometimes anonymise your personal data, so that you cannot be identified from the data, in which case we may use it without further notice to you.  Once you are no longer a member of our staff, we will retain and securely destroy your personal information accordance with our Data Retention Policy.

 

WHAT RIGHTS DO YOU HAVE IN RELATION TO YOUR PERSONAL DATA?

Under some circumstances you may:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data where there is no good reason for our continuing to process it.
• Object to processing your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing your personal data. This means you can ask us to suspend the processing of personal information about you, if (for example) you would like us to establish its accuracy.
• Request the transfer of your personal data to a third party.

You also have the right to withdraw consent, in the limited circumstances under which you have been asked for and provided your consent to our processing your personal data.

You have the right to raise any concerns about how your personal data is being processed with the Information Commissioner’s Office (ICO) by going to the ICO’s website:  https://ico.org.uk or contacting the ICO on 0303 123 1113 or casework@ico.org.

If you would like information on these rights, please speak to Elliot Gold, our Data Protection Officer, on Elliot Gold, email address eg@work.life.