Internal Privacy Policy

Keep Britain Tidy Workforce Privacy Policy

 

Keep Britain Tidy aims to process information about you fairly, lawfully, and in a transparent manner. This policy applies to current and former employees, job candidates, workers and volunteers. This notice does not form part of any contract of employment or other contract to provide services. We may update this policy at any time.

Keep Britain Tidy 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 policy.

It is important that you read this policy, together with any other privacy policy or 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.

Our contact details

Name: Keep Britain Tidy (Registered in England and Wales under the registered charity number 1071737 and as a limited company registered under the company number 3496361).

Address: Elizabeth House, The Pier, Wigan, WN3 4EX.

Telephone Number: 01942 612 621 

Email: dataprotection@keepbritaintidy.org

Web address: www.keepbritaintidy.org

The types of personal information we collect

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
• Your date of birth;
• Your gender;
• Marital status and dependents;
• Next of kin and emergency contact information;
• Your 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 and car insurance details
• Recruitment information (including copies of right to work documentation processed either by Keep Britain Tidy or via a third party processor, references and other information included in a CV or cover letter or as part of the application process);
• Details of any publicly accessible social media posts prior to appointment;
• Employment records (including job titles, work history, working hours, training records and professional memberships);
• Performance information;
• Disciplinary and grievance information.
• CCTV footage;
• Information about your use of our information and communications systems; and
• Photographs.

 

We may also collect, store and use the following "special categories" of more sensitive personal information:

 

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• Information about your health, including any medical condition, health and sickness records;
• Information about criminal convictions and offences.

 

How we collect your personal information

We collect personal information about employees, job candidates, workers and volunteers 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, agencies or other background check agencies. We may also collect information about employees, workers and volunteers through their publicly accessible social media accounts prior to being offered a role with us.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

Legal basis for using your personal information

We will only use your personal information when the law allows us to. Your personal information is usually processed for one of the following reasons under data protection law:

 

• where we need it comply with a contractual obligation, or take steps to enter into a contract 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 have obtained your consent;
• where we need to protect your interests (or someone else's interests);
• where it is needed in the public interest.

 

Legal basis for using your sensitive personal information

 

Where we process more sensitive “special categories of personal data”, your personal information is usually processed for one of the following reasons under data protection law:

 

• in limited circumstances, where you have provided your explicit consent;
• where we need to carry out our legal obligations or exercise our rights in connection with employment;
• where it is needed in the public interest, for example for equal opportunities monitoring;
• where it is necessary to protect you or another person from harm;
• where it is needed in relation to legal claims.

 

How we use your personal information

 

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 relevant 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;
• 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, volunteers 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 and Social Media policies;
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and
• Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

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;
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting;

 

Criminal Convictions

We envisage that we will hold information about criminal convictions.

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.

Where we process criminal data, our legal basis for doing so are:

• for the performance of a task in the public interest; and
• in order to protect the public under the Data Protection Act 2018.

Data Sharing

We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so.

Where necessary or required, we may share your personal information as follows:

• With third-party service providers, in connection with services performed on our behalf, such as payroll and HR services, and to process data in support of our purposes listed above.  
• With government bodies, the Charity Commission and law enforcement agencies.
• With our insurers and legal advisers.
• With our auditors and accountants.
• With third parties to whom we may choose to sell, transfer or merge parts of our charity or our assets. Alternatively, we may seek to acquire other charities or merge with them. If a change happens to KBT, then the new trustees may use your personal data in the same way as set out in this privacy policy.

This list is not exhaustive as there are other circumstances where we may also be required to share information, for example:

• To meet our legal obligations.
• In connection with legal proceedings (or where we are instructed to do so by Court order).

Our relationships with third party service providers are governed by contractual provisions with us and they only have access to personal information to perform the described purposes and may not use it for other purposes.

Third parties that KBT currently use who may process your personal data and the purpose for which your data is processed:

 

Applied

https://www.beapplied.com/

Recruitment software - Applicant tracking system and recruitment administration

 

Cushion

https://www.cushon.co.uk/

Pension Provider: Pension Provider: Employee Number, Name, status, DOB, Gender, NI Number, Nationality, postal address, email address, employment start date, monthly or fortnightly salary details.

 

Childcare Vouchers

https://www.mychildcarevouchers.co.uk/

Provision of childcare vouchers to employees

 

Concur

https://us2.concursolutions.com/

Processing of cash and credit card expenses

 

DriverCheck

www.drivercheck.co.uk/privacy-policy/

Licence check: Name, DOB, Driver number, Address, Email Address, Vehicle details (including registration number, make and model, date of 1st registration, road tax expiry, MOT expiry, MOT certificate number, Insurance Co., Insurance Policy number, Insurance expiry, type of cover, details of leavers.

 

Essential Skills - WorkWize

https://www.essentialskillz.com/

Training: Name, email address, department, location, details of training, details of leavers (archive).

 

 

Friends Life

www.aviva.co.uk/legal/privacy-policy.html

Life Insurance: Name, gender, DOB, NI number, salary, job title, location, details of leavers.

 

Microsoft Teams

https://privacy.microsoft.com/en-gb/privacystatement

Staff and team meetings

 

PayCheck

https://paycheck.co.uk/

Payroll process: employee and worker name, status, nationality, email address, job title, NI number, contract details, P45/46 for tax purposes, annual salary, DOB, Address, Bank details. Also receive notification (under processing of salary) for: maternity, childcare vouchers, paternity leave, shared parental leave, pension contribution, cyclescheme contributions, details of leavers, employee number.

 

PeopleHR

https://www.peoplehr.com/

HR administration: records including name, email address, postal address, telephone number, employee number, emergency contacts, location of work, department, DOB, NI number, start date, gender, job title, salary details, nationality, employment type, documents relating to your employment, right to work details, DBS details (where applicable to role),

 

Scottish Widows

https://www.scottishwidows.co.uk/

Pension Provider: Employee Number, Name, status, DOB, Gender, NI Number, Nationality, postal address, email address, employment start date, monthly or fortnightly salary details.

 

BUPA

https://www.bupa.com/Corporate/legal-notices/privacy-policy)

Employee Assistance Provider: Name, email address, postal address, location of work, DOB, NI number, date of salary paid, start date, level of cover, details of leavers.

 

CycleScheme

www.ourprivacycommitments.com/

Any individual data is input independently into the scheme, however we hold the following information internally upon sign up: Name, email address, postal address, salary sacrifice information,

 

Broadstone

https://www.broadstone.co.uk/privacy-policy/

Employee Number, Job Title, Name, status, DOB, Gender, NI Number, Nationality, postal address, email address, telephone number, employment start date, salary details, pension details

 

TrustID

https://www.trustid.ch/en/data-protection-policy

We use TrustID as an authentication service provider to complete online right to work checks in accordance with legislation and collect the following information:

Passport information, I.e. Name, email address, date of birth, photograph, passport number, nationality, gender, place of birth, date of issue and expiry, country of issue

 

How we store your personal information

Your information is securely stored on a secure private network.

We may transfer your personal information outside the UK and European Economic Area (EEA). For example, some of our external third-party service providers may be based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA.

Whenever we transfer your personal information out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
• Where there is a specific exemption under data protection law which will permit us to make the transfer outside the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

How long we keep your personal information

We will only retain 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.

In general, we will keep your details in accordance with the following:

Contact details	6 years post-employment
Right to work including age details and passport information (including photograph)	6 years post-employment
Pay details	6 years post-employment
Annual leave details	6 years post-employment
Sick leave/absence details	6 years post-employment
Performance details	6 years post-employment
Disability/health details	6 years post-employment
Contact details	6 years post-employment
Qualifications	6 years post-employment
Employment history	6 years post-employment
Ethnicity	6 years post-employment
Personal information collected as part of a recruitment campaign
Disability/health details	6 years post-employment
Contact details	6 months post-campaign
Qualifications	6 months post-campaign
Employment history	6 months post-campaign
Ethnicity	6 months post-campaign
Potential disability/health details if disclosed	6 months post-campaign

 

Your data protection rights

Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information.
• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not generally required to pay any charge for exercising your rights. If you make a request we generally have one month to respond to you, unless we have a legal ground to extend this deadline. Please note, there are some specific circumstances where these rights do not apply, and we can refuse to deal with your request.

Your right to withdraw consent

In the circumstances where you may have provided your consent to the processing of your personal information, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details above. 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.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at:

dataprotection@keepbritaintidy.org 

or by writing to us at:

The Data Protection Officer, Elizabeth House, The Pier, Wigan, WN3 4EX. 

You can also contact us by telephone Number on 01942 612 621.

If you are unhappy with how we have used your data, you can also complain to the Information Commissioner’s Office. The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

 

Changes to this Privacy Policy

This privacy policy was last updated in November 2023. This privacy policy does not form part of your contract of employment, and we reserve the right to update this privacy policy at any time. We may also notify you in other ways from time to time about the processing of your personal information.