Boparan Private Office Limited is the parent company for a number of subsidiaries (the Group).
This notice (together with any other documents referred to in it) applies to Applicants, Employees, Former Employees and Pension Scheme Members. It sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by the Group.
The position is different depending on who you are – please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1. Scope
This notice explains how we handle the personal information of applicants, employees, former employees, dependents, beneficiaries and temporary agency workers in the course of our human resources activities. This notice may be amended or updated from time to time and may also be supplemented by other statements to comply with local site requirements, or where employees’ representation agreements exist.
2. Information we may collect about you
- We may process your personal information for legitimate business purposes to administer our employment or contractual relationship with you and to run our businesses.
- We may collect, use and transfer your personal information through automated, electronic and/or paper-based data processing systems. We have established routine processing functions (such as processing for regular payroll and benefits administration).
- We also process personal information on an occasional or ad hoc basis (such as when an employee is being considered for a particular new position or in the context of changes to their marital status for example).
- In the normal course of human resources activities, we can collect, store and use the following types of personal information:
- Personal identification information, such as your name, home address, date of birth, sex, work- related photographs, and home phone number;
- Government-issued identification numbers, such as your national insurance number or national ID for payroll purposes;
- Immigration, right-to-work and residence status;
- Family and emergency contact details;
- Job-related information, such as years of service, work location, employment ID, work record, vacation absences, and contract data;
- Educational and training information, such as your educational awards, certificates and licenses, vocational
- records and in-house training attendance;
- Recruitment and performance-related data, such as objectives, ratings, comments, feedback results, career history, work equipment, career and succession planning, skills and competencies and other work-related qualifications;
- Information related to your usage of Group assets;
- Information needed for compliance and risk management, such as disciplinary records, background check reports and security data; and
- Payroll and payment or benefits-related information, such as salary and insurance information, dependents, government identifier or tax numbers, bank account details, and employment related benefits information.
- We may also collect, store and use the following more sensitive types of personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions;
- Trade union membership;
- Information about your health, including any medical condition and sickness records, including:
- where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill health, injury or disability, the records relating to that decision;
- details of any absences (other than holidays) from work including time on statutory parental leave and sick leave;
- any health information in relation to a claim made under the permanent health insurance scheme; and
- where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
- biometric data;
- Information about criminal convictions and offences.
- We take reasonable steps to ensure that personal information is accurate, complete, and current. Please note that you have shared responsibility with regard to the accuracy of your personal information. Please notify your HR team of any changes to your personal information or that of your beneficiaries or dependents.
3. Ways we might use your personal information
- The purposes for which we may process personal information include the following:
- workforce planning, recruitment and staffing;
- workforce administration, payroll, compensation and benefit programs;
- performance management, learning and development;
- advancement and succession planning;
- legal compliance, including compliance with government authority requests for information;
- workplace management, such as travel and expense programs and internal health and safety programs;
- internal reporting;
- audit;
- to protect the Group, its workforce, and the public against injury, theft, legal liability, fraud or abuse;
- when reasonably necessary in the event of an urgent business need or emergency, including a life-threatening emergency, a cyber incident, suspected unauthorised access to systems or data, or another incident requiring urgent action to protect the Group, its workforce, customers, systems, information, property or legal rights; and
- other legal and customary business-related purposes.
Special categories of particularly sensitive personal information
- Certain sensitive personal information (such as information about your health, racial or ethnic origin, trade union membership or biometric data) requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal We have in place assessments and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
- in limited circumstances, with your explicit written consent;
- where we need to carry out our legal obligations or exercise rights in connection with employment;
- where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme;
- where it is necessary to protect you or another person from
- 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.
Situations in which we might use your sensitive personal information
- In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below.
- We will use information about your physical or mental health, or disability status, to:
- ensure your health and safety in the workplace;
- assess your fitness to work;
- provide appropriate workplace adjustments;
- monitor and manage sickness absence; and
- administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance.
- We need to process this information to exercise rights and perform obligations in connection with your employment.
- If you leave employment and under any share plan operated by us the reason for leaving is determined to be ill health, injury or disability, we will use information about your physical or mental health, or disability status, in reaching a decision about your entitlements under the share plan.
- If you apply for an ill-health pension under a pension arrangement, we will use information about your physical or mental health in reaching a decision about your entitlement.
- If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being.
- 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.
- We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.
- We will use information about your physical or mental health, or disability status, to:
Do we need your consent?
- We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we might 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 do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.
4. Disclosure of your Personal Information
- You agree that we have the right to share your personal information with:
- any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries (as defined in section 1159 of the UK Companies Act 2006), and the Boparan Holdings Limited Group;
- any prospective seller or buyer of our business;
- any third-party company(ies) providing HR, payroll, benefits administration or other employment-related services and/or software, where those companies are engaged by our Group or by the wider Boparan Holdings Limited Group;
- a third party:
- if we are under a duty to do so in order to comply with any legal obligation or for the performance of any contract we enter into with them or you;
- to protect the rights, property or safety of the Group, our customers or others (e.g. for the purposes of fraud protection and credit risk reduction);
- for employment verification purposes; and/or
- when reasonably necessary such as in the event of a life-threatening emergency.
5. Where we store your Personal Information
- Please note the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, administration of benefits arrangements, and provision of support services. However, we will not transfer personal data outside of the European Economic Area unless there are appropriate safeguards in accordance with applicable data protection law.
- Unfortunately, the transmission of information via the internet is not completely Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
6. Your Rights
You have the right to ask us not to process your personal data for the above purposes where such processing is not required by law, necessary for the fulfilment of a contractual obligation, or required to meet a legitimate need of the Group as an employer.
7. Access to Information
- You may reasonably access and update the personal information pertaining to you that is on file with the Group. You can exercise this right by contacting your HR team. Please note that your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval, or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.
- If you believe that any information we are holding on you is incorrect, incomplete or out of date, please contact your HR team who will promptly correct any information found to be