Home Pet People GDPR
Home Pet People GDPR Privacy Policy Notice (Internal) The purpose of this document Home Pet People is committed to protecting the privacy and security of your personal information. Home Pet People ICO registration No. 4350186 This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulations (GDPR). It applies to all employees, workers and contractors. Home Pet People 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, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. It is important that you read this notice, together with any other privacy notice we may provide 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. Data protection principles We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely. 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). We may 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. • Date of birth.
• Gender.
• Marital status and dependants.
• Next of kin and emergency contact information.
• National Insurance number.
• Bank account details, payroll records and tax status information.
• Salary, annual leave, pension and benefits information.
• Start date.
• Location of employment or workplace.
• Copy of driving licence or passport (where applicable for your job role).
• 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).
• Employment records (including job titles, work history, working hours, training records and professional memberships).
• Compensation history.
• Performance information.
• Disciplinary and grievance information.
• Information about your use of our information and communications systems.
• CCTV footage and other information obtained through electronic means.
• Photographs. We may 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
Information about criminal convictions and offences.
How is your personal information collected
We typically collect personal information about employees, workers and contactors through the application and recruitment
process, either directly from candidates or sometimes from an employment agency or background check provider. We may
sometimes collect additional information from third parties including former employers, credit reference agencies or other
background check agencies.
Whilst you are working with us periodically we may need to collect additional personal information from you not identified on the
above list but before doing so we will provide you with a written notice setting out details of the purpose and the lawful basis of
why we are collecting that data, its use, storage and your rights.
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 we need to perform the contract we have entered into with you.
• Where we need to comply with a legal obligation.
• 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.
We may also use your personal information in the following situations, which are likely to be rare:
• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
We need all the categories of information in the list above, primarily to allow us to perform our contract with you and to enable
us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own
or those of third parties, provided your interests and fundamental rights do not override those interests. 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.
• Providing benefits to you.
• Liaising with your pension provider.
• Administering 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 for possible grievance or disciplinary 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 monitor your use of our information and communication systems to ensure compliance with our IT policies.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic
communications systems and preventing malicious software distribution.
• To conduct data analytics studies to review and better understand employee retention and attrition rates.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal
information.
If you fail to provide personal information
If you fail to provide information which we believe is necessary for the performance of the contractual employment
relationship (for example bank account details to pay you) or our associated legal obligations (for example giving salary
information to HMRC). If you fail to provide certain information when requested, we may not be able to meet our contractual
obligations to you or we may not be able to fulfil our legal obligations.
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 purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.
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 may process special categories of personal
information in the following circumstances:
• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations and in line with our privacy policy.
• Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension
scheme, and in line with our privacy policy.
• Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may 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. We may also process such information about members or former members in the course of
legitimate business activities with the appropriate safeguards.
Our obligations as an employer
We will use your particularly sensitive personal information in the following ways:
• We will use information relating to leaves of absence, which may include sickness absence or family related leaves, 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 exercise specific rights in the field of employment law.
In limited circumstances, we may 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.
Information about criminal convictions
We envisage that we will hold information about criminal convictions.
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such
processing is necessary to carry out our obligations and provided we do so in line with our privacy policy.
Less commonly, we may use information relating to criminal convictions 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 if 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 as part of the recruitment process or we
may be notified of such information directly by you in the course of you working for us.
We will use information about criminal convictions and offences in the following ways:
• To ensure your employment with the company is appropriate and does not jeopardise the reputation of the business
• To ensure any vulnerabilities are not exposed
• To ensure ex-offenders’ anonyminity is, where appropriate, protected
• We are allowed to use your personal information in this way to carry out our obligations as your employer.
Automated decision making
It is our intention that you will not be subject to automated decision making which will have a significant impact on you, unless
we have a lawful reason for doing so and we have notified you.
Data sharing
In order to meet our legal obligations connected with your employment relationship it is necessary to share your personal
information with certain third parties (see below). We also need to share your data when we have legitimate business reasons for
doing so and also where it is necessary in order to perform your contract.
Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the working
relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers, including contractors and designated agents. The following activities are
carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services,
training provision (not required by law), HR and occupational health and welfare provisions.
How secure is my information with third-party service providers?
Third party service providers are only permitted to process your personal data in accordance with our specified instructions. They
are also required to take appropriate measures to protect your privacy and personal information. We do not allow your
information to be used by the third parties for its own purposes and business activities.
Transferring personal information out of the European Economic Area (EEA)
We do not transfer personal data outside the EEA
Data security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
We will notify you and any applicable regulator of any suspected unauthorised use of your personal data.
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 our Data Protection Controller.
When your employment relationship comes to an end with our business we will either retain or securely destroy your personal
data in accordance with our data retention policy or other applicable laws and regulations.
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.
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.
• 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.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal
data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection
Controller in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge
a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the
request in such circumstances.
What we may need from you – confirmation of identity
Whenever you make a request for access to personal data, we may request and keep a copy of specific information to confirm
your identity. This is usually done to ensure that we are releasing personal data to the correct person.
Right to withdraw consent
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 your consent, please contact our Data Protection Controller. 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 Protection Controller & Complaints
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Controller Felicity
Kienstra (Director) email: felicity@homepetpeople.live-website.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information
Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information
Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire , SK9 5AF, England.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make
any substantial updates. We may also notify you in other ways from time to time about the processing of your personal
information.
