Staff privacy notice
ICON PRIVACY NOTICE FOR STAFF AND PROSPECTIVE STAFF
WHAT IS THE PURPOSE OF THIS DOCUMENT?
Imperial Consultants (ICON) is a “data controller”. This means that we are responsible for deciding how we hold and use the personal information we hold about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to staff, members and applicants for any vacancies that we may advertise. 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 which has been pseudonymised or anonymised to the extent that the individual can no longer be identified (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.
- Marital status and dependants.
- Details of your professional activities and membership of professional associations.
- 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.
- College CID number.
- Recruitment information (including copies of right to work documentation, references and other information included your completed application form, 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.
- CCTV footage and other information obtained through electronic means such as swipecard records, which is recorded and held by College as part of College Security.
- Information about your employment and professional life after leaving us, where relevant (for example, where you have asked us to keep in touch with you).
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.
- Information concerning your racial or ethnic origin, sex life or sexual orientation (for example, in the course of investigating complaints made by you or others, for example concerning discrimination).
- Information about certain criminal convictions (for example, where this is necessary for due diligence purposes, compliance with our legal obligations or employment law).
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect most of the personal information about you, via your completed application form, your completed HR forms or Occupational Health Assessments, in person, and in the course of your employment. We may sometimes collect additional information from third parties including e.g. (among others) former employers or other background check agencies.
How we will use information about you and the legal basis for processing your data under the GDPR
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:
1. For the performance of a contract (such as your employment contract) to which you are a party or in order to take steps at your request prior to entering into a contract.
2. Where we need to comply with a legal obligation.
3. 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.
4. Where it is necessary in order to protect your vital interests or someone else’s vital interests.
5. Where you have consented to the processing.
SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION
We need all the categories of information in the list above
The kind of information we hold about you primarily allows 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. We have indicated by bullet points the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.
(I) PERFORMANCE OF A CONTRACT WITH YOU
We process your personal data because it is necessary for the performance of a contract to which you are party or in order to take the steps at your request prior to entering into a contract, such as a contract of employment or other engagement with us. In this respect, we use your personal data for the following:
- Administering job applications and, where relevant, offering a role with us.
- Making a decision about for e.g., your recruitment or appointment.
- Carrying out due diligence checks on you, whether during your application process for a role with us, or during your engagement with us, including by checking references in relation to your education and your employment history.
- Once you are employed or engaged by us in any capacity, for the performance of the contract of employment (or other agreement) between you and us.
- To pay you and to administer benefits (including pension) in connection with your employment or other engagement with us.
- Monitoring your attendance (including absence) and your performance in your work, including in performance appraisals.
- For disciplinary purposes including conducting investigations where required.
- For other administration purposes, for example to update you about changes to your terms and conditions of employment or engagement, or changes to your pension arrangements, etc.
- For internal record-keeping, including the management of any staff feedback or complaints.
(II) LEGITIMATE INTERESTS
We process your personal data because it is necessary for our or a third party’s legitimate interests. Our “legitimate interests” include our interests in running the ICON in a professional, sustainable manner, in accordance with all relevant legal and regulatory requirements. In this respect, we use your personal data for the following:
- Providing you with information about us and what it is like to work for us (where you have asked for this, most obviously before you have made a formal application to work for us).
- For security purposes, including by operating security cameras in various locations on the College’s premises and the production of photo ID cards.
- To enable relevant authorities to monitor the ICON’s performance and to intervene or assist with incidents as appropriate.
- To carry out or cooperate with any ICON or external complaints, disciplinary or investigatory process.
- To administer the ICON’s regulations, codes of practice and policies.
- For the purposes of management planning and forecasting, research and statistical analysis and benchmarking.
- In connection with organising events and administration of your social and sporting activities (e.g. relating to your use of the College’s sports facilities).
- Contacting you or your family members and ‘next of kin’ for business continuity purposes, to confirm your absence from work, etc.
- Publishing your image and likeness in connection with your employment or engagement with us.
- Promoting ICON and its goods, services, events and resources, unless it is appropriate to gain your specific consent.
- To monitor (as appropriate) use of the ICON’s IT and communications systems in accordance with the ICON’s Information Security Policy.
- Monitoring your performance in your work, including in performance appraisals, educational, training and development requirements.
- Making decisions about salary reviews and compensation.
- To ensure the information we hold about you is up to date and accurate.
- To ensure that content from our site is presented in the most effective manner for you and your computer or mobile device.
- Equal opportunities monitoring.
(III) LEGAL OBLIGATIONS
Your personal data will also be processed by ICON for compliance with the ICON’s legal obligations. For example:
- To meet our legal obligations (for example, relating to child protection, diversity and gender pay gap monitoring, employment, health and safety.
- For tax purposes, including transferring personal data to HM Revenue and Customs to ensure that you have paid appropriate amounts of tax, and in respect of any Gift Aid claims, where relevant.
- For compliance with immigration laws and rules.
- For the prevention and detection of crime, and in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
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 certain information when requested, we may not be able to perform the contract we have entered into with you and we may be prevented from complying with our legal obligations (such as reporting requirements of the HMRC).
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:
1. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data.
2. Where it is necessary in the context of employment law, or laws relating to social security and social protection.
3. Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent.
4. Where the processing relates to personal data which have been manifestly made public by you.
5. Where the processing is necessary for the establishment, exercise or defence of legal claims, or for courts acting in their judicial capacity.
- We will use your particularly sensitive personal information in the following ways:
- Your physical or mental health or condition(s) (for example, where required to monitor and record sickness absences, dietary needs, or to make reasonable adjustments to your working conditions or environment – including as part of the recruitment process if necessary).
- Recording your racial or ethnic origin in order to monitor our compliance with equal opportunities legislation.
- Trade union membership, in connection with your rights as an employee and our obligations as an employer (to the extent necessary).
- Categories of your personal data which are relevant to investigating complaints made by you or others, for example concerning discrimination.
- Categories of your personal data which are relevant to administering family friendly leave.
- We will also process special categories of personal data because:
- It is necessary to protect your or another person’s vital interests, for example, where you have a life-threatening accident or illness in the workplace and we have to process your personal data in order to ensure you receive appropriate medical attention;
- It is necessary for the establishment, exercise or defence of legal claims; or
- We have your explicit consent to do so.
- Criminal convictions
- You will be asked to provide ICON with details of criminal convictions where your role, or a project you volunteer or are employed to undertake requires a DBS check. A DBS check will only be conducted under the lawful process provided for by law. We will only use the criminal convictions data for the purpose it was collected and it will only be retained for a limited period as set out in ICON’s Retention Policy (see the section overleaf: How long will you hold my information for?).
DO WE NEED YOUR CONSENT?
We do not need your consent to process sensitive personal information if we use special categories of your personal information ensure your health and safety in the workplace and to assess your fitness to work and to ensure meaningful equal opportunity monitoring and reporting. 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.
We may have to share your data with third parties, including third-party service providers and other entities in the College group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
If we do, you can expect a similar degree of protection in respect of your personal information.
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 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 designated agents), other entities within the College group and third party suppliers who are acting as data processors for Imperial Consultants. For example, we will share your data with
- providers of employee benefits,
- the College, IT providers, and other employees, clients, agents or contractors where there is a legitimate reason for their receiving the information.
We may also share your information with:
- our auditors (internal and external);
- professional advisors;
- a potential or future employer where they have requested a reference from us;
- or a Court, government body, law enforcement agency or other authority (for example, HM Revenue) when we are required to do so.
HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS AND OTHER ENTITIES IN OUR GROUP?
All our third-party service providers and other entities in the College group 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.
WHAT ABOUT OTHER THIRD PARTIES?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business and operations of ICON (e.g. third parties processing data on our behalf as part of administrating the provision of benefits including pensions etc.). 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.
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.
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 and they are subject to a duty of confidentiality.
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.
INTERNATIONAL TRANSFERS OF DATA
Imperial Consultants, and the College, will, in limited circumstances, disclose personal data to third parties, or allow personal data to be stored or handled, in countries outside the UK, including those deemed third countries’.
- For example, we will transfer data to: partner institutions or organisations who are based in other countries; and
- IT or other service providers based overseas.
In these circumstances, your personal data will only be transferred on one of the following bases: • the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. data transfer assessments and standard data protection contract clauses adopted by the European Commission and UK Government respectively);
- a UK Adequacy decision which provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
- Implementation of the UK International Data Transfer Agreement or UK Addendum in cases where the EU Standard Contract Clauses are utilised.
- there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent or it forms part of a contractual requirement)
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 records ICON holds are included in our retention policy which is available on this website: [Link]. 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.
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 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)
- 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 the College’s Data Protection Officer in writing, who is responsible for dealing with requests on behalf of ICON staff.
Please note that the above rights are not absolute, and requests may be refused where exceptions apply. You can find out more about your rights at www.ico.org.uk.
DATA PROTECTION OFFICER
College have appointed a Data Protection Officer, who is responsible acting on behalf of ICON staff to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how ICON handle your personal information, please contact the Data Protection Officer at:
Imperial College London
Data Protection Officer
Faculty Building Level 4
London SW7 2AZ
e-mail: [email protected]
CONTACT AND COMPLAINTS
The ICO does recommend you seek to resolve any issues with the data controller initially prior to any referral to it. If you have any queries about this privacy notice or how we process your personal data, or if you wish to exercise any of your rights under applicable law, you may contact your line manager or the Data Protection Officer whose details are set out in the section Data controller and Data Protection Officer details above.
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.
Last updated on 22 May 2018
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