WHO WE ARE – THE DATA CONTROLLER
‘We’ are SHS Group Limited, a company incorporated and registered in Northern Ireland with company number NI011256 whose registered office is at SHS House, 199 Airport Road West, Belfast, Co. Antrim, BT3 9ED.
We are the “Controller” for the purposes of data protection law. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, the legal basis for processing your personal data and details of long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
WHAT INFORMATION DO WE HOLD AND HOW DO WE OBTAIN IT?
Personal data means any information about an individual from which that person can be identified. There are 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 may hold and use various types of personal data about you, including, for example, biographical details, recruitment information, details of your terms of employment, pay and
benefits details, CCTV footage, performance information, health and safety information, disciplinary and grievance matters, details of holiday and other leave, photographs, mobile telephone numbers, location information and information about your use of our information and communication systems.
We may also hold and use the following “special categories” of more sensitive personal information including information about your race or ethnicity, religious beliefs, sexual orientation and political opinions, trade union membership, information about your health, including any medical condition, health and sickness records, genetic information and information about criminal convictions and offences.
We will only collect information about criminal convictions where the law allows us to do so.
OUR PURPOSE FOR COLLECTING DATA AND THE LEGAL GROUNDS
We hold and use personal data for employment, HR and business administration purposes for example your application form and references, your contract of employment and any amendments to it; correspondence with or about you, for example letters to you about a pay rise or, at your request, a letter to your mortgage company confirming your salary; information needed for payroll, benefits and expenses purposes; contact and emergency contact details; records of holiday; and records relating to your career history, such as training records, appraisals, other performance measures and, where appropriate, disciplinary and grievance records etc.
Data protection law specifies the legal grounds on which we can hold and use personal data. Most commonly, we rely on one or more of the following legal grounds when we process your personal data:
The sort of special category data that we hold and use includes: information relating to your health, which could include reasons for absence and GP reports and notes, equal opportunities monitoring data, biometric data and details of family leave which could include information about your health, religious beliefs, sexual life or sexual orientation. Information such as this may be used to manage absence and ensure cover, accommodate health conditions and consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate. We will also need this data to administer and manage statutory and company sick pay, and health insurance.
Since special category data is usually more sensitive than most ordinary personal data, we are required to have an additional legal ground to process it. Most commonly, in addition to at least one of the legal grounds above, we rely on one or more of the following grounds to process your special category data:
Occasionally, we may also hold and use ordinary personal data: in the public interest for the detection or prevention of crime; or where needed to protect your vital interest or those of another person. We may also occasionally hold and use special category data: to establish, exercise or defend a legal claim; where needed to protect your interests (or someone else’s interest) where you are not capable of giving your consent; or where you have already made the information public.
Sometimes we may use your personal data for purposes that are different from or incompatible with those for which we collected it. If we do this, we will notify you and explain our legal ground for using your data in this way, as required under data protection law.
You have fundamental rights over your personal data. These are explained in detail in the Information Commissioners Website and we are committed to making it as simple as possible for you to exercise them.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw consent, please contact the Data Compliance Manager. 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.
DO WE NEED YOUR CONSENT TO PROCESS PERSONAL DATA?
We do not need your consent if we use your personal information to carry out our legal obligations, legitimate interests or exercise specific rights in the field of employment law as outlined above. In limited circumstances, we may approach you for written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it so that you can consider whether you wish to consent. You should be aware that providing the requested information is not a condition of your contract.
To protect your data we have put in place security precautions which include but are not limited to:
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Our Company data is stored in the following locations:
DATA SHARING AND TRANSFERRING
For the purposes of GDPR, we are resident in the United Kingdom and regulated by the Information Commissioner’s Office. We do not carry out any data processing outside of the EEA; if that changes, we will inform you.
We will only share your personal data with third parties where we have an appropriate legal grounds under data protection law which permits us to do so. Where we transfer any data to a third party we have put in place all necessary controls to ensure the protection of privacy.
Other third parties include, for example, disclosure to:
When SHS does outsource the processing of Personal Data to third parties or provide Personal Data to third party service providers, we require those third parties to protect the Personal Data they are provided with appropriate security measures and prohibit them from using the Personal Data for their own purposes or from disclosing the Personal Data to others.
Your data will be stored in accordance with our retention policy, and is dependent upon the nature of the record. A copy of our Records Retention, Protection and Erasure Policy can be obtained from Human Resources or on our intranet.
If you have any questions about us or how we handle your data, please contact The Data Compliance Manager us at firstname.lastname@example.org.
Note too that you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Details of how to contact the ICO can be found on its website: http://ico.org.uk