Data Lead for Employees: Mary Carter-Lee, Head of HR
The Club collects and processes personal data relating its employees to manage the employment relationship. The Club is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the Club collect?
The Club collects and processes a range of information about you. This includes the following; however, this is not an exhaustive list:
- 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 Club
- information about your remuneration, including entitlement to benefits such as pensions or insurance cover
- details of your bank account and national insurance number
- your car registration details for access to Woodcote Park
- 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 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 appraisals, performance reviews and ratings, performance improvement plans and related correspondence
- information about medical or health conditions, including whether or not you have a disability for which the Club needs to make reasonable adjustments
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief
- photographs for internal information, security site access, to provide staff with information about staff events, videos for recruitment purposes etc.
The Club may collect this information in a variety of ways. For example, data might be collected through application forms and CVs, 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.
In some cases, the Club may collect 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 will be stored securely in a range of different places, electronic and hard copy, including in your personnel file, in the Club's HR management systems and in other IT systems (including the Club's email system).
Why does the Club process personal data?
The Club needs to process data to 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.
In some cases, the Club 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.
In other cases, the Club has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the Club 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 Club 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
- maintain and promote equality in the workplace.
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).
Where the Club processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring.
Who has access to data?
Your information may be shared internally, including with members of the HR and recruitment 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 Club 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 Club also shares your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits, the provision of occupational health services, the provision of performance management processing including 360 feedback.
The Club will not transfer your data to countries outside the European Economic Area.
How does the Club protect data?
The Club takes the security of your data seriously. The Club 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. Relevant policies include the Data Protection Policy and Information Security Policy.
Where the Club 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.
For how long does the Club keep data?
The Club will hold your personal data for the duration of your employment and post employment, in certain instances some data will be held for extended periods of time to enable us to comply with legal, pension and health and safety legislation or in permanent preservation in-line with the heritage purposes of the Club. The periods for which your data is held after the end of employment are set out in the employee data retention schedule.
As a data subject, you have a number of rights. You can:
- correct any data we hold about you that is not correct (Rectification)
- have any data not covered by our retention policy deleted (Erasure)
- block or suppress the further processing of your personal data in certain circumstances (Restriction)
- request access to personal data that we hold about you (Subject Access)
- in some circumstances, receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and have this transmitted to another data controller (Data Portability)
- withdraw consent where this is the legal basis for us processing your information
- object to processing where the Club is relying on its legitimate interests as the legal ground for processing
If you would like to exercise any of these rights, please refer to the Data Protection Policy.
If you believe that the Club has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You have some obligations under your employment contract to provide the Club 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 Club 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 the Club to enter a contract of employment with you. If you do not provide other information, this will hinder the Club's ability to administer the rights and obligations arising as a result of the employment relationship efficiently.