GDPR Privacy notice for employees, workers and contractors (UK)
1. What is the purpose of this document?
We Love Pets is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to current and former employees, and candidates for new positions. This notice does not form part of any contract of employment or other contract to provide services. This notice can be updated at any time and we will inform you if this occurs.
It is important that you read this notice, together with any other privacy notice that is provided on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
2. Data protection principles
We Love Pets is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with data protection law, including the General Data Protection Regulation (GDPR).
It applies to all employees, agents, interns, workers and contractors.
We will comply with data protection law. This says that the personal information we hold about you 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 those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
3. The kind of information we hold about you
Personal data, or personal information, 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 “special categories” of more sensitive personal data which require a higher level of protection.
We collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Dates of birth
- Emergency contacts
- National Insurance number.
- Bank account details, payroll records and tax status information.
- Salary, annual leave, pension and benefits information.
- Start date and leaving date.
- Copy of driving licence, passport or birth certificate
- 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).
- Full employment records (including contract, terms and conditions, job titles, work history, working hours, promotion, absences, attendances, training records and professional memberships).
- Performance and appraisal information.
- Disciplinary and grievance information.
- Information about your use of our information and communications systems.
- Photographs and videos.
- Accident book, first aid records, injury at work and third-party accident information.
- Evidence of your right to work in the UK/immigration status
In some instances, and only when legally permissible by law also collect, store and use the following “special categories” of more sensitive personal information:
Information about your health, including any medical condition, health and sickness records.
4. How is your personal information collected?
We typically collect personal information about employees, agents, interns, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from a background check provider. We will sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies, including:
- Disclosure Barring Service (DBS)
- Police checking service
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.
5. How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where it is necessary for performing the contract, we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is in the public interest to do so; or for official purposes.
There can be rare occasions where it becomes necessary to use your personal information to protect your interests (or someone else’s interests).
Situations in which we will use your personal information
We need all the categories of information in the list above (see: The kind of information we hold about you) to enable us to perform our role as employer; to enable us to comply with legal obligations.
The situations in which we will process your personal information are listed below.
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the UK.
- Paying you and, if you are an employee, deducting tax and
- National Insurance contributions.
- Liaising with your pension provider, providing information about changes to your employment such as promotions, changing in working hours.
- General administration of the contract we have entered into with you.
- Business management and planning, including accounting and auditing.
- Conducting performance reviews, managing performance and determining performance requirements.
- Making decisions about salary reviews and compensation.
- Assessing qualifications for a particular job or task, including decisions about promotions.
- Gathering evidence and any other steps relating to possible grievance or disciplinary matters and associated hearings.
- Making decisions about your continued employment or engagement.
- Making arrangements for the termination of our working relationship.
- Education, training and development requirements.
- Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
- Ascertaining your fitness to work, managing sickness absence.
- Complying with health and safety obligations.
- To prevent fraud.
- To conduct data analytics studies to review and better understand employee retention and attrition rates.
- Equal opportunities monitoring.
- Some of the purposes will overlap and there can be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we will not be able to fully perform the contract we have entered with you (such as paying you or providing a benefit), or we could be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
Change of purpose
We will only use your personal information 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 information for an unrelated or new purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we will if necessary, process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We will, if necessary, process special categories of personal information in the following circumstances:
- Where we need to carry out our legal obligations or exercise our employment-related legal rights and in line with our data protection policy
- Where it is in line with our data protection policy, it is substantially in the public interest to do so and necessary for:
a. equal opportunities monitoring.
b. administering our pension scheme
c. preventing or detecting unlawful acts
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
In some circumstances, we will process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Our obligations as an employer
We will use your particularly sensitive personal information in the following ways:
We will use information relating to leave of absence; this can include sickness absence or family related leave, to comply with employment and other laws.
We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations, or for one of the other reasons outlined in the box above: ‘How we use particularly personal information’. In limited circumstances, if the need arises, we will approach you for your 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 carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
7. Information about criminal convictions
We will only use information relating to criminal convictions or alleged criminal behaviour where the law allows us to do so. This can arise when it is necessary for us to comply with the law or for another reason where there is a substantial public interest in us doing so.
Less commonly, we will, if necessary, use information relating to criminal convictions or alleged criminal behaviour where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We will only collect information about criminal convictions or allegations of criminal behaviour where it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions/allegations as part of the recruitment process or if we are notified of such information directly by you in the course of you working for us.
We are allowed to use your personal information in this way where it is in line with our data protection policy and where one of the following reasons arises:
Where we need to carry out our legal obligations or exercise our employment-related legal rights;
Where it is substantially in the public interest to do so.
We will collect additional information from third parties including former employers or other background check agencies, including:
- Disclosure Barring Service (DBS)
- Police checking service
This is part of our vetting procedure, because you will hold customers keys and will be entering customer premises.
8. Data sharing
We will in some circumstances have to share your data with third parties
- Other branches, if you are carrying out work for them
- We Love Pets Limited (Head Office) for the purpose of updating you, providing you with information and sending newsletters.
- HMRC to pay your Tax and Nat Insurance
- Customers, if required to carry out the service
- Licensing team in local authorities for the purpose of obtaining, keeping and renewing any animal related licenses.
We require third parties to respect the security of your data and to treat it in accordance with the law.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary administer the working relationship with you or where it is in the public interest to do so. This will, in some circumstances, involve sharing special categories of personal data and, where relevant, data about criminal convictions/allegations.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services, security vetting.
How secure is my information with third-party service providers?
All our third-party service providers 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.
When might you share my personal information with other organisations within We Love Pets?
We will share your personal information with other We Love Pets organisations as part of our regular reporting activities on performance, in the context of a business reorganisation or restructuring exercise, for system maintenance support and hosting of data; business planning/talent management initiatives, succession planning, statistical analysis; and general management and functioning of We Love Pets
What about other third parties?
If required, we will need to share your personal information with a regulator or to otherwise comply with the law.
9. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
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.
10. Data retention
How long will you use my information for?
We will only retain your personal information 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 information are available in our retention policy which is available from: https://welovepets.care/legal/privacy-policy
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 will anonymise your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with [our data retention policy or applicable laws and regulations].
11. Rights of access, correction, erasure, and restriction Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. Please contact your manager to update these.
12. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
What we need from you
We sometimes 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 information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you 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 your consent, please contact your 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.
Data enquiries and breaches
All data breaches or enquires should be directed to the branch owner.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time. We will also notify you in other ways from time to time about the processing of your personal information.