Employee Privacy Notice
For Plan International UK’s general Privacy Notice, please see our website.
This privacy notice covers the specific personal data Plan International UK collects and processes relating to its employees to manage the employment relationship. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does Plan International UK collect?
The organisation collects and processes a range of information about you. This includes (as applicable):
- information provided by you such as 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 organisation
- information about your pay and benefits
- details of your bank account and national insurance number
- information about your marital status, next of kin, dependants and emergency contacts
- information about your nationality and entitlement to work in the UK
- information from references
- information on DBS checks including the outcome of the checks
- details of your work pattern (days of work and working hours)
- details of periods of leave taken by you, including holiday, sickness and other absence, 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
- performance management information, including appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence
- information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief
- other relevant information as applicable required by Plan UK in order to ensure we fulfil our obligations as an employer.
The organisation collects this information in a variety of ways. For example, data is collected through application forms and CVs; obtained from your passport or other identity documents; 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. You are also able to directly update some of the information held on your record on Cascade, the organisation’s HR Information System, and to view the other fields in your record.
In some cases, the organisation collects personal data about you from third parties, such as references supplied by former employers and information from criminal records checks permitted by law.
Data is stored in a range of different places, including in your personnel file, in the organisation's HR management systems, the time tracking system and in other IT systems (including the organisation's network drives and email system).
Why does Plan International UK process personal data?
The organisation 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 benefits such as your pension and life insurance.
In some cases, the organisation 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, to enable employees to take periods of leave to which they are entitled, and to consult with employee representatives where this is a legal requirement. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question.
In other cases, the organisation has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the organisation to:
- run recruitment 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
- 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 or health conditions which are having an impact on their ability to carry out their role, 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 organisation 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
- conduct employee engagement surveys
- provide references on request for current or former employees
- respond to and defend against legal claims
- maintain and promote equality, diversity and inclusion in the workplace.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
Some special categories of personal data (also known as ‘sensitive personal data’), such as information about health or medical conditions, are processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).
Where the organisation 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. Data that the organisation uses for these purposes is anonymised or is collected with the express consent of employees, which can be withdrawn at any time. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so. Records are stored on the HR system and employees can amend or delete the data should they wish to do so.
Who has access to data?
Your information will 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 senior managers and IT staff if access to the data is necessary for performance of their roles.
Your data could also be shared with employee representatives in the context of collective consultation on a redundancy or merger, if such a situation were to arise. This would be limited to the information needed for the purposes of consultation, such as your name, role and length of service.
The organisation shares your data with third parties in order to obtain pre-employment references from other employers and to obtain necessary criminal records checks from the Disclosure and Barring Service. The organisation may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.
The organisation also shares your data with third parties that process data on its behalf, in connection with payroll, currently provided by Cascade, the provision of benefits such as life insurance and pensions and the provision of occupational health services.
Your data (e.g. mobile number) may also be shared for the purposes of the organisation’s Business Continuity Plan or Serious Incident Group procedures.
Your data may also be shared for the purposes of audit or donor compliance.
Your data may be transferred to countries outside the European Economic Area (EEA) for information required within Plan International or for audit or compliance purposes. Data will only be transferred outside the EEA where required and where adequate safeguards such as an International Data Agreement or contract are in place.
How does Plan International UK protect data?
The organisation takes the security of your data seriously. The organisation 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. These include the Data Protection Policy, the Data Retention Policy (PDF) and the Unstructured Personal Data Standard.
Where the organisation 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 Plan International UK keep data?
How long we retain your data is governed by our Data Retention Policy (PDF). After you leave the organisation, we will retain only key information such as job and salary records after one year and will delete your record entirely after 6 years, unless we are required to maintain data for a longer period for compliance or donor reporting reasons.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request
- require the organisation to change incorrect or incomplete data
- require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing
- ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact the organisation’s Data Protection Officer either directly or by emailing ‘UKNO Data Protection Officer’.
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner’s Office (ICO).
What if you do not provide personal data?
You have some obligations under your employment contract to provide the organisation 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 organisation 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 organisation to enter a contract of employment with you. If you do not provide other information, this will hinder the organisation's ability to administer the rights and obligations arising as a result of the employment relationship efficiently.
Employment decisions are not based solely on automated decision-making.
Last updated: 22 March 2019