Privacy Policy - Employees, Contractors & Job Applicants (Policy version 2019/01 - last reviewed October 2019/last approved January 2020)

Exeter Friendly Society Limited (known as ‘The Exeter’) collects and processes personal data relating to:

·            Employees to manage the employment relationship

·            Temporary Staff & Contractors to manage the employment relationship

·            Job applicants to consider suitability for employment

The Exeter is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

1.         What information does The Exeter collect?

The Exeter collects and processes a range of information about Employees, temporary staff, contractors and job applicants ('You’, ‘Your’). This may include:

·           Your name, address and contact details, including email address and telephone number, date of birth and gender;

·           the terms and conditions of Your employment;

·           details of Your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with The Exeter;

·           information about Your remuneration, including entitlement to benefits such as pensions or insurance cover;

·           details of Your bank account and national insurance number;

·           information about Your marital status, next of kin, dependants and emergency contacts;

·           information about Your nationality and entitlement to work in the UK;

·           information about any adverse financial history You may have (if appropriate to You);

·           information about Your criminal record;

·           details of Your schedule (days of work and working hours) and attendance at work;

·           details of periods of leave taken by You, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave;

·           details of any disciplinary or grievance procedures in which You have been involved, including any warnings issued to You and related correspondence;

·           assessments of Your performance, including performance conversations, reviews and ratings, training You have participated in, performance improvement plans and related correspondence;

·           information about medical or health conditions, including whether or not You have a disability for which The Exeter needs to make reasonable adjustments; and

·           equal opportunities monitoring information, including information about Your ethnic origin, sexual orientation, health and religion or belief.

The Exeter collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from Your passport or other identity documents such as Your driving licence; from forms completed by You at the start of or during employment (such as benefit nomination forms); from correspondence with You; or through interviews, meetings or other assessments. It is the responsibility of the employee / contractor / job applicant to ensure each party consents to The Exeter holding their data.

In some cases, The Exeter collects personal data about You from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records checks permitted by law.

Data is stored in a range of different places, including in Your personnel file, in The Exeter's HR management systems and in other IT systems (including The Exeter's email system).

2.         Why does The Exeter process personal data?

The Exeter needs to process data to consider suitability for employment and enter into an employment contract with You and to meet its obligations under Your employment contract. For example, it needs to process Your data to provide You with an employment contract, to pay You in accordance with Your employment contract and to administer benefit, pension and insurance entitlements.

The Exeter also needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee's entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question.

In other cases, The Exeter has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows The Exeter to:

·           run recruitment and promotion processes;

·           maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;

·           operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;

·           operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;

·           operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;

·           obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;

·           operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that The Exeter complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;

·           ensure effective general HR and business administration;

·           provide references on request for current or former employees;

·           respond to and defend against legal claims; and

·           maintain and promote equality in the workplace.

Where The Exeter relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not. This will include using your personal image and photographs, including for community and charity committee events, unless you indicate otherwise.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).

If You are provided with benefits as an Employee, for example Private Medical Insurance, a separate Privacy Policy will be applicable.

Your information will be shared internally, including with members of the HR team (including payroll), Your line manager, managers in the business area in which You work and IT staff if access to the data is necessary for performance of their roles.

The Exeter shares Your data with third parties in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service. The Exeter may also share Your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

The Exeter also shares Your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits and the provision of occupational health services.

The Exeter will not transfer Your data to countries outside the European Economic Area without Your consent.

4.         How does The Exeter protect data?

The Exeter takes the security of Your data seriously. The Exeter has internal policies and controls in place to try to ensure that Your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties

We are committed to ensuring that Your Personal Information is secure. To prevent unauthorised access or disclosure, We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information We collect, including ISO 27001 accreditation.

Where The Exeter engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

5.         For how long does The Exeter keep data?

The Exeter will hold Your personal data for the duration of Your employment. The periods for which Your data is held after a job application or at the end of employment are:

·           Job applicants – 6 months after the application or interview process has ended

·           Employees & Contractors – 7 years from the termination of employment (regardless of reason for leaving the company).

6.         Your rights

As a data subject, You have a number of rights. You can:

·           access and obtain a copy of Your data on request;

·           require The Exeter to change incorrect or incomplete data;

·           require The Exeter to delete or stop processing Your data, for example where the data is no longer necessary for the purposes of processing;

·           object to the processing of Your data where The Exeter is relying on its legitimate interests as the legal ground for processing; and

·           ask The Exeter to stop processing data for a period if data is inaccurate or there is a dispute about whether or not Your interests override The Exeter's legitimate grounds for processing data.

If You would like to exercise any of these rights, please contact our Data Protection Officer.

7.         What if You do not provide personal data?

You have some obligations under Your employment contract to provide The Exeter with data. In particular, You are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide The Exeter with data in order to exercise Your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that You are unable to exercise Your statutory rights.

Certain information, such as contact details, Your right to work in the UK and payment details, have to be provided to enable us to enter a contract of employment with You. If You do not provide other information, this will hinder our ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

8.         Automated decision-making

Employment decisions are not based solely on automated decision-making.

9.         Complaints

In the event of a complaint regarding the Personal Information We hold, please refer to Our Complaints Procedure or contact Our Data Protection Officer.

10.       Changes to Our Privacy Policy Employees, Contractors & Job Applicants

We will review and amend this Policy periodically. When this Policy is amended, We will not usually inform individuals that have provided Personal Information to Us of the changes We make.

11.       Data Protection Officer

For any further information on this Policy, to make a subject access request or to exercise Your rights under the UK data protection legislation, please contact Our Data Protection Officer, Mandy.Tonkin@the-exeter.com.