For Job Applicants

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective employees of our Company, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

A) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal data

B) TYPES OF DATA HELD
We keep several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.
Specifically, we hold the following types of data:
a) personal details such as name, address, phone numbers;
b) name and contact details of your next of kin;
c) your photograph;
d) your gender, marital status, information of any disability you have or other medical information;
e) right to work documentation;
f) information on your race and religion for equality monitoring purposes;
g) information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
h) references from former employers;
i) details on your education and employment history etc;
j) driving licence;
k) criminal convictions.

C) COLLECTING YOUR DATA
You provide several pieces of data to us directly during the recruitment exercise.
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.
Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.

D) LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data

Lawful basis

Carrying out checks in relation to your right to work in the UK

Legal obligation

Making reasonable adjustments for disabled employees

Legal obligation

Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion

Our legitimate interests

Making decisions about salary and other benefits

Our legitimate interests

Making decisions about contractual benefits to provide to you

Our legitimate interests

Assessing training needs

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your:
a) health
b) sex life
c) sexual orientation
d) race
e) ethnic origin
f) political opinion
g) religion
h) trade union membership
i) genetic and biometric data.
We carry out processing activities using special category data:
a) for the purposes of equal opportunities monitoring
b) to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) You have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.
G) CRIMINAL CONVICTION DATA
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, may also be collected during your employment. We use criminal conviction data to determine your suitability, or

your continued suitability for the role. We rely on the lawful basis of Our legitimate interests to process this data.

WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.

Data is shared with third parties for the following reasons: Our legitimate interests

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

PROTECTING YOUR DATA

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.

RETENTION PERIODS

We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year.

If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.

AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. 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.

YOUR RIGHTS

You have the following rights in relation to the personal data we hold on you:

the right to be informed about the data we hold on you and what we do with it;

the right of access to the data we hold on you. We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly;

the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;

the right to have data deleted in certain circumstances. This is also known as ‘erasure’;

the right to restrict the processing of the data;

the right to transfer the data we hold on you to another party. This is also known as ‘portability’;

the right to object to the inclusion of any information;

the right to regulate any automated decision-making and profiling of personal data.

In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data 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 Mak Desai, via
email : mak.desai@m3j.co.uk

MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

DATA PROTECTION COMPLIANCE

Our appointed compliance officer in respect of our data protection activities is:

Mak Desai
mak.desai@m3j.co.uk

For Contractors

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

A. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

1. 1. processing is fair, lawful and transparent
   2. data is collected for specific, explicit, and legitimate purposes
   3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
   4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
   5. data is not kept for longer than is necessary for its given purpose
   6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
   7. we comply with the relevant GDPR procedures for international transferring of personal data

 

B. TYPES OF DATA HELD

We keep several categories of personal data about you in order to carry out effective and efficient processes. We keep this data in a file relating to each contractor and we also hold the data within our computer systems, for example, our accounts systems.

Specifically, we hold the following types of data:

1. personal details such as name, address, phone numbers
2. your photograph
3. your gender
4. marital status
5. bank account details
6. payment rates
7. CCTV footage
8. Building access card records

 

C. COLLECTING YOUR DATA

You provide several pieces of data to us directly during any contract negotiation period, for example your name and address, and subsequently upon the start of your engagement, for example, your bank details.

In some cases, we will collect data about you from third parties, such as intermediaries who may act as an introducer.

Personal data is kept in files or within the Company’s HR and IT systems.

D. LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement, in order to perform the contract we have with you or in pursuit of our legitimate interests.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data	Lawful basis
Carry out the contract that we have entered into with you e.g. using your name, contact details	Performance of the contract
Ensuring you receive payment	Performance of the contract
Making decisions about who to enter into a contract with	Our legitimate interests
Business planning and restructuring exercises	Our legitimate interests
Dealing with legal claims made against us	Our legitimate interests
Preventing fraud	Our legitimate interests
Ensuring our administrative and IT systems are secure and robust against unauthorised access	Our legitimate interests

E. SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

1. 1. health
   2. sex life
   3. sexual orientation
   4. race
   5. ethnic origin
   6. political opinion
   7. religion
   8. trade union membership
   9. genetic and biometric data.

 

Most commonly, we will process special categories of data when the following applies:

1. you have given explicit consent to the processing
2. we must process the data in order to carry out our legal obligations
3. we must process data for reasons of substantial public interest
4. you have already made the data public.

 

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

F. FAILURE TO PROVIDE DATA

 

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you or performing the contract that we have entered into.

G. CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of the services you are to provide to us and where the law permits us. This data will usually be collected during contract negotiation, however, may also be collected during your engagement. We use criminal conviction data to determine your suitability, or your continued suitability for the engagement. We rely on the lawful basis of Our legitimate interests to process this data.

H. WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.

Data is shared with third parties for the following reasons: for the administration of payroll

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

I. PROTECTING YOUR DATA

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.

J. RETENTION PERIODS

We only keep your data for as long as we need it for, which will be at least for the duration of your engagement with us though in some cases we will keep your data for a period after your engagement has ended. Our retention period is 5 years

K. AUTOMATED DECISION MAKING

 

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. 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.

L. DATA SUBJECT RIGHTS

You have the following rights in relation to the personal data we hold on you:

1. 1. the right to be informed about the data we hold on you and what we do with it
   2. the right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Requests
   3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’
   4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’
   5. the right to restrict the processing of the data
   6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’
   7. the right to object to the inclusion of any information
   8. the right to regulate any automated decision-making and profiling of personal data.

 

More information can be found on each of these rights in our separate policy on your rights in relation to your data.

M. CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

N. MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

O. DATA PROTECTION COMPLIANCE

 

Our Data Protection Officer is:

Mak Desai

07376048481

Mak.desai@m3j.co.uk

For Employees / Workers

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our employees, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

This notice applies to current and former employees and workers.

A) DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance

with these principles, we will ensure that:

. Processing is fair, lawful and transparent

. Data is collected for specific, explicit, and legitimate purposes

. Data collected is adequate, relevant and limited to what is necessary for the purposes of processing

. Data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay

. Data is not kept for longer than necessary for its given purpose

. Data is processed in a manner that ensures appropriate security of personal data including protection against

unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisatiomeasures

. We comply with the relevant GDPR procedures for international transferring of personal data

B) TYPES OF DATA HELD

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our password protected computer

systems, for example, our holiday booking system.

Specifically, we hold the following types of data, as appropriate to your status:

. Personal details such as name, address, phone numbers

. Name and contact details of your next of kin

. Your photograph

. Your gender, marital status, information of any disability you have or other medical information

. Right to work documentation

. Information on your race, religion and ethnicity for equality monitoring purposes

. Information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter

. References from former employers

. Details on your education and employment history etc

. National Insurance numbers

. Bank account details

. Tax codes

. Driving licence

. Details of your vehicle insurance

. Details of your vehicle MOT

. Details of your CBT

. Details of your tracker data

. Pictures of your vehicle and delivery box

. Details of any disclosure and Criminal convictions

. CCTV footage details involving you

. Building access card records

. IT equipments use including telephones, internet access and password protected IT System

. Information relating to your employment with us, including:

> Job t

itle and job descriptions

> Y

our salary

> Y

our wider terms and conditions of employment

>Details of formal and informal pr

oceedings involving you such as letters of concern, disciplinary and griev ance proceedings, your annual leave records, appraisal and performance information

> Internal and external training modules undertaken

> Informat

ion on time off from work including sickness absence, family related leave etc

C) COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment.

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 files or within the Company’s HR and IT systems.

D) LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the employment contract we have with you, including ensuring you are paid correctly.

The information below categorises the types of data processing, appropriate to your status, we undertake and the lawful basis we rely on.

Activity requiring your data	Lawful basis
Carry out the employment contract that we have	Performance of the contract
entered into with you e.g. using your name, contact
details, education history, information on any disci-
plinary, grievance procedures involving you
Ensuring you are paid	Performance of the contract
Ensuring tax and National Insurance is paid	Legal obligation
Carrying out checks in relation to your right to work	Legal obligation
in the UK
Making reasonable adjustments for disabled em-	Legal obligation
ployees
Making recruitment decisions in relation to both	Our legitimate interests
initial and subsequent employment e.g. promotion
Making decisions about salary and other benefits	Our legitimate interests
Ensuring efficient administration of contractual	Our legitimate interests
benefits to you
Effectively monitoring both your conduct, including	Our legitimate interests
timekeeping and attendance, and your perfor-
mance and to undertake procedures where neces-
sary
Maintaining comprehensive up to date personnel	Our legitimate interests
records about you to ensure, amongst other things,
effective correspondence can be achieved and
appropriate contact points in the event of an emer-
gency are maintained
Implementing grievance procedures	Our legitimate interests
Assessing training needs	Our legitimate interests
Managing statutory leave and pay systems such as	Our legitimate interests
maternity leave and pay etc
Business planning and restructuring exercises	Our legitimate interests
Dealing with legal claims made against us	Our legitimate interests
Preventing fraud	Our legitimate interests
Ensuring our administrative and IT systems are se-	Our legitimate interests
cure and robust against unauthorised access
Providing employment references to prospective em-	Legitimate interest of the prospective employer
ployers, when our name has been put forward by the
employee/ex-employee, to assist with their effective
recruitment decisions

E) SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

. health

. sex life

. sexual orientation

. race

. ethnic origin

. political opinion

. religion

. trade union membership

. genetic and biometric data.

We carry out processing activities using special category data:

. for the purposes of equal opportunities monitoring

. in our sickness absence management procedures

. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

. you have given explicit consent to the processing

. we must process the data in order to carry out our legal obligations

. we must process data for reasons of substantial public interest

. you have already made the data public.

F) FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract

of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

G) CRIMINAL CONVICTION DATA

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, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role.

We rely on the lawful basis of our legitimate interest to process this data.

H) WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR. Data is shared with third parties for the following reasons:

. For the administration of payroll

. Your location based on tracking system will be shared to our client to maintain our legitimate interest

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We share your data with bodies outside of the European Economic Area. These countries are India and the reason for sharing with these countries is our IT system is being managed by the off shore contractors based in India. We have put the following measures in place 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 EU and UK data protection laws:

. The contractors have been given secure login details in where trail can be audited

. The contractors have been given privacy notice in line with GDPR

I) PROTECTING YOUR DATA

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.

J) RETENTION PERIODS

We only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended. Some data retention periods are set by the law. Our retention periods are: Retention periods can vary depending on why we need your data, as set out below:

. Up to 5 years from the end date of en employment

K) AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. 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.

L) EMPLOYEE RIGHTS

You have the following rights in relation to the personal data we hold on you:

. the right to be informed about the data we hold on you and what we do with it;

. the right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Requests;

. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;

.the right to have data deleted in certain circumstances. This is also known as ‘erasure’;

. the right to restrict the processing of the data;

.the right to transfer the data we hold on you to another party. This is also known as ‘portability’;

. the right to object to the inclusion of any information;

the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.

M) CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

N) MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

O)DATA PROTECTION COMPLIANCE

Our Data Protection Officer is: Mak Desai
07376048481
Mak.desai@m3j.co.uk