Staff Privacy Notice
What is the purpose of this document?
The Hurlingham Club 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 the General Data Protection Regulation (GDPR).
It applies to all employees, workers and contractors.
The Club is registered with the Information Commissioners Office as a Data Controller. This means that we are responsible for deciding how we hold and use personal information about you. This notice does not form part of any contract of employment or another contract to provide services. We may update this notice at any time.
The kind of information we hold about you
As your employer, the Club may collect and hold a range of different information about you. This allows us to manage our employment relationship with you, provide Club services efficiently and comply with our obligations as an employer.
We will collect, store, and use the following categories of personal information about you:
(a) Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
(b) Date of birth.
(d) Next of kin and emergency contact information, including on occasion, information on family members.
(e) National Insurance number.
(f) Bank account details, payroll records and tax status information.
(g) Salary, bonus, commission, annual leave, pension and other benefits information.
(h) Start date.
(i) Location of employment or workplace.
(j) Copy of driving licence (if you drive a Club vehicle).
(k) Recruitment information (including copies of right-to-work documentation which includes nationality, references and other information included in a CV or cover letter or as part of the application process).
(l) Employment records (including job titles, work history, working hours, clocking in and out records, other absence records, training records and professional memberships).
(m) Performance information.
(n) Disciplinary and grievance information.
(o) CCTV footage and other information obtained through electronic means such as swipecard records.
(p) Information about your use of our information and communications systems.
(r) Correspondence with or about you.
There are Special Categories of more sensitive personal data which require a higher level of protection under the GDPR. We may also collect, store and use the following:
(a) Information about your health, including any medical conditions, health and sickness records.
(b) Biometric data such as fingerprint scans and hand shape scans.
(c) Information about criminal convictions and offences.
How is your personal information collected?
We 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.
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.
How will we use information about you?
We will only use your personal information when the law allows us to. The GDPR sets out a number of different reasons for which an organisation may collect and process your data.
We rely on the following legal bases:
(a) Where we need to perform the contract we have entered into with you.
(b) Where we need to comply with a legal obligation.
(c) 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.
(d) In specific situations, we will collect and process your information with your consent. We will always make it clear to you what you are consenting to and what information is necessary for which services.
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.
(a) Making a decision about your recruitment or appointment.
(b) Determining the terms on which you work for us.
(c) Checking you are legally entitled to work in the UK.
(d) Paying you and, if you are an employee or worker, deducting tax and National Insurance contributions.
(e) Providing benefits to you, for example, healthcare or travel insurance.
(f) Liaising with your pension provider.
(g) Administering the contract we have entered into with you.
(h) Business management and planning, including accounting and auditing.
(i) Conducting performance reviews, managing performance and determining performance requirements.
(j) Making decisions about salary reviews and compensation (including bonuses and commission).
(k) Assessing qualifications for a particular job or task, including decisions about promotions.
(l) Gathering evidence for possible grievance or disciplinary hearings.
(m) Making decisions about your continued employment or engagement.
(n) Making arrangements for the termination of our working relationship.
(o) Education, training and development requirements.
(p) Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
(q) Ascertaining your fitness to work.
(r) Managing sickness absence.
(s) Complying with health and safety obligations.
(t) To prevent fraud.
(u) To monitor your use of our information and communication systems to ensure compliance with our IT policies.
(v) To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
(w) To conduct data analytics studies to review and better understand employee retention and attrition rates.
(x) Equal opportunities monitoring.
(y) Using CCTV cameras to view and record individuals at the Club to help maintain a safe and secure environment for our staff, members and visitors. Signage and information is available on CCTV locations around the Club and storage of footage. If you have any queries regarding CCTV usage, please contact the IT & Communications Executive.
(z) To fulfil our safeguarding obligations, this includes carrying out Disclosure and Barring Service (DBS) checks on a regular basis for staff carrying out certain roles. More information regarding this can be found in the Safeguarding Policy.
(aa) Internal staff communication such as the staff newsletter sent by email and administering Staff Council.
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 certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
How we use particularly sensitive personal information
Special Categories of particularly sensitive personal information require higher levels of protection. We may process special categories of personal information in the following circumstances:
(a) In limited circumstances, with your explicit written consent.
(b) Where we need to carry out our legal obligations and in line with our data protection policy.
(c) Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our data protection policy.
(d) 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 will use your particularly sensitive personal information in the following ways:
(a) 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.
(b) 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.
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so.
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 from you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:
(a) To make recruitment decisions.
(b) To carry out our safeguarding obligations.
We do not envisage that any decisions will be taken about you using automated means, however, we will notify you in writing if this position changes..
We may have to share your data with third parties, including third-party service providers. We will do this 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. We require third parties to respect the security of your data and to treat it in accordance with our policies and the law. We do not allow our third-party service providers to use your personal data for their own purposes.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
The following activities are carried out by third-party service providers: some recruitment, electronic communications, pension administration, benefits provision and administration, training administration, payroll and tax administration (HMRC), support of employment records software, and employment law.
We may share your personal information with other third parties, for example in the context of the restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
We have put in place measures to protect the security of your information and to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
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.
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. 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 may anonymise your personal information so that it can no longer be associated with you, in which case we may 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 schedule.
Rights of access, correction, erasure and restriction
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.
Under certain circumstances, by law, you have the right to:
(a) 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.
(b) 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.
(c) 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).
(d) Object to the 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.
(e) 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.
(f) 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 the Human Resources Manager in writing.
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.
We may 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 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 the Human Resources 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.
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.
If you have any questions about this privacy notice, please contact the Human Resources Manager.