Ultimate Battery Company (UBC) is aware of its obligations under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 and is committed to Processing your data securely and transparently. This privacy notice sets out the types of data that we retain on you as an employee of UBC. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This notice applies to job applicants, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors.
UBC is a Data Controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:
Ultimate Battery Company Limited
Address: Thurcroft Industrial Estate, New Orchard Lane, Thurcroft, Rotherham S66 9ER
Telephone: 01709 914777
In relation to your personal data, we will:
We hold many types of data about you, including:
We collect data about you in a variety of ways and this will usually start when we undertake a recruitment exercise where we will collect the data from you directly. This includes the information you would normally include in a CV, application form or a recruitment cover letter, or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving license, passport, or other right to work evidence.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Personal data is kept in personnel files or within UBC’s HR and IT systems
The law on data protection allows us to process your data for certain reasons only:
All the Processing carried out by us falls into 1 of the permitted reasons. Generally, we will rely on the first 3 reasons set out above to process your data. For example, we need to collect your personal data in order to:
We also need to collect your data to ensure we are complying with legal requirements such as:
We also collect data so that we can carry out activities which are in the legitimate interests of UBC. We have set these out below:
Special categories of data are data relating to your:
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, it may also be collected during your employment. We use criminal conviction data in the following ways:
One of the reasons for Processing your data is to allow us to carry out our duties in line with your contract with us. If you do not provide us with the data needed to do this, we will be unable to perform those duties e.g. ensuring you are paid correctly. We may also be prevented from confirming, or continuing with, your employment with us in relation to our legal obligations if you do not provide us with this information e.g. confirming your right to work in the UK or, where appropriate, confirming your legal status for carrying out your work via a criminal records check.
Your data will be shared with colleagues within UBC where it is necessary for them to undertake their duties. This includes, for example, your line manager for their management of you, HR for maintaining personnel records and the payroll department for administering payment under your contract.
We share your data with third parties if we are legally obliged to do so or where we need to comply with our contractual duties to you. For instance, we may need to pass on certain information to an external consultant who is supporting our grievance, capability or disciplinary processes, as well as our pension, benefits or health insurance providers. Where we have the requirement to use an intermediary, we will ensure that they are fully GDPR compliant before engaging with them.
We do not share your data with bodies outside of the European Economic Area. However, if we were to do so, we will put in place measures to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred, process it in a way required by UK data protection laws.
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction, and abuse. We have implemented processes to guard against such.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with current data protection requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
Data will only be kept for as long as is necessary to fulfil the purpose identified or as required by law. Where there is a legal requirement to keep the data, we will comply with the statutory retention periods. All pay records will be retained for a period of 6 full financial years. All other personnel records will be retained for a period of 6 years following the end of employment.
Any recruitment data for unsuccessful applicants will be destroyed six months after the completion of the recruitment exercise.
A full list of data retention periods is provided in the Data Protection Policy (Appendix C – Data Retention Schedule).
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
Where you have provided consent for the Processing of particularly Sensitive Data (genetic or biometric data) you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop Processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so. If you wish to exercise any of the rights explained above, please contact the Chief Operating Officer.
The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
UBC’s Data Protection Officer is Paul Mitchell, he can be contacted at: [email protected]
This policy applies to the Processing of personal data in manual and electronic records kept by Ultimate Battery Company Limited (UBC) in connection with its human resources function as described below. It also covers UBC’s response to any data breach and other rights under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
UBC makes a commitment to ensuring that personal data, including special categories of personal data and criminal offence data (where appropriate) is processed in line with data protection law and all its employees conduct themselves in line with this and other related policies. Failure to do so may lead to disciplinary action, including dismissal, and may also constitute a criminal offence.
Where third parties process data on behalf of UBC, UBC will ensure that the third party takes such measures in order to maintain UBC’s commitment to protecting data.
This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, workers, and self-employed contractors. These are referred to in this policy as Relevant Individuals. A glossary of other terms used in this policy can be found in Appendix A.
Personal data is kept in personnel files or within UBC’s HR systems.
Relevant individuals should refer to UBC’s Privacy Notice for more information on the types of data held, reasons for its Processing activities, the lawful bases it relies on for the Processing and data retention periods.
All personal data obtained and held by UBC will:
In addition, personal data will be processed in recognition of an individual’s data protection rights, as follows:
Relevant individuals have a right to be informed whether UBC processes personal data relating to them and to access the data that UBC holds about them. Requests for access to this data will be dealt with under the following summary guidelines:
Relevant individuals must inform UBC immediately if they believe that the data is inaccurate, either as a result of a subject access request or otherwise. UBC will take immediate steps to rectify the information.
Forcing employees to obtain information via a subject access request, usually in relation to an individual’s criminal record, is a criminal offence. No employee of UBC will be required to make a subject access request.
For further information on making a subject access request please refer to the Subject Access Procedure in Appendix B.
UBC may be required to disclose certain data/information to a third party. The circumstances leading to such disclosures include:
These kinds of disclosures will only be made when strictly necessary for the purpose.
UBC adopts procedures designed to maintain the security of data when it is stored and transported.
In addition, employees must:
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised by the Data Controllers. Where personal data is recorded on any such device it should be protected by:
UBC does not transfer personal data to any recipient outside of the EEA. Data stored on “cloud” platforms outside of the UK will be compliant with UK laws.
Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the Data Protection Officer who is required to inform the Information Commissioner within 72 hours of UBC becoming aware of it. The breach may be reported in more than 1 instalment.
Relevant Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual.
New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated Data Controllers/auditors/Data Protection Officers for UBC are trained appropriately in their roles under data protection legislation.
All employees who need to use the computer system are trained to protect individuals’ personal data, to ensure data security, and to understand the consequences to them as individuals and UBC of any potential lapses and breaches of UBC’s policies and procedures.
UBC keeps records of its Processing activities including the purpose for the Processing and retention periods in Appendix C. These records will be kept up to date so that they reflect current Processing activities.
If you have any concerns or wish to exercise any of your rights under the GDPR, then you can contact the Chief Executive or Chief Operating Officer (UBC’s Data Controllers).
In their absence you can contact Paul Mitchell at: [email protected] (UBC’s Data Protection Officer).
Data Controller – the Data Controller decides what Personal Information UBC will hold and how it will be held or used.
Data Protection Officer – the person responsible for ensuring that UBC follows its Data Protection Policy and complies with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
Relevant Individual/Data Subject – The person whose Personal Information is being held or processed by UBC for example: an employee, worker or contractor.
Explicit Consent – is a freely given, specific and informed agreement by Relevant Individual in the Processing of Personal Information about her/him. Explicit Consent is needed for Processing Sensitive Data.
Information Commissioner – The UK Information Commissioner responsible for implementing and overseeing the data protection law.
Processing – means collecting, amending, handling, storing, or disclosing Personal Information.
Personal Information – Information about living individuals that enables them to be identified – e.g. name and address. It does not apply to information about organisations, companies and agencies but applies to named persons, such as individual employees or other workers within UBC.
Sensitive Data – refers to data about:
Subject access requests must be made in writing and can be made in either hard copy format or electronically. HR can provide you with a form for making a request, though making a request in this format is not a requirement. Including specific details of the data you wish to see in your request will enable a more efficient response from UBC. We may need to contact you for further details on your request if insufficient information is contained in the original request.
Requests may be made by you personally or by a third party e.g. a solicitor acting on your behalf. We will request evidence that the third party is entitled to act on your behalf if this is not provided at the same time as the request is made.
Subject UBC will comply with your request without delay and at the latest within 1 month unless 1 of the following applies:
Before supplying the data we may contact you asking for proof of identity. You must produce this evidence for your request to be complied with.
Subject UBC may refuse to comply with a subject access request if it is manifestly unfounded or excessive/repetitive. In these circumstances, we will write to you without undue delay and at the latest within 1 month of receipt to explain why we are unable to comply. You will be informed of the right to complain to the Chief Operating Officer in the first instance. If you remain dissatisfied with the response from the Chief Operating Officer, you can complain to the Information Commissioner.
All requests will be considered carefully in the context of which they are made. The request may be manifestly unfounded if the following applies:
The request may be excessive if the following applies:
|Tax and Social Security|
|Record of Taxable Payments||6 years (+1 year)||CIPD recommend retention of all salary and wage payments for 6 years|
|Record of Tax Deducted or Refunded||6 years (+1 year)|
|Record of Earnings||6 years (+1 year)|
|Record of earnings on which standard NICs payable||6 years (+1 year)|
|Record of employer’s and employee’s NICs||6 years (+1 year)|
|NIC contracted out arrangements||6 years (+1 year)|
|Copies of notices to employee e.g, P45, P60||6 years (+1 year)|
|Inland Revenue notice of code changes, pay and tax details||6 years (+1 year)|
|Expenses Claims||6 years (+1 year)|
|Record of sickness payments||6 years (+1 year)|
|Record of maternity, adoption, paternity and shared parental leave payments||6 years (+1 year)|
|Redundancy details and record of payments & refunds||6 years (+1 year)|
|Inland Revenue approvals||Permanently||CIPD Recommendation|
|Actuarial Valuation Reports||Permanently||CIPD Recommendation|
|Detailed returns of pension fund contributions||Permanently||Legal Requirement|
|Annual reconciliations of fund contributions||Permanently||Legal Requirement|
|Investment policies/Pension Records||12 years from end of benefits payable||CIPD Recommendation|
|Records relating to retirement benefits||6 years (+1 year)|
|All employee correspondence including terms & conditions of service, both general terms applicable to all employees, and specific applying to individuals.||6 years after employment ceases||CIPD Recommendation|
|References provided for former employees||1 year|
|Training Programmes||6 years after completion||Commercial|
|Individual Training Records||6 years after employment ceases||CIPD Recommendation|
|Shortlists, interview notes and related application forms||6 months|
|Health and Safety Records|
|Medical records relating to control of asbestos/ control of substances hazardous to health (COSHH)||Permanently||CIPD Recommendation|
|Health & Safety assessments||Permanently|
|Health & Safety Policy statements||Permanently|
|Records of consultations with safety representatives||Permanently|
|Accident records/reports/accident books||6 years after date of last entry||Limitation for legal proceedings|
|Sickness records||6 years from end of sickness|