Employee Privacy Notice

Data controller: ATB Group UK Ltd, Hardy Road, Norwich, NR1 1JN

The organisation collects and processes personal data 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.

The organisation collects and processes personal data on one or more of the legal bases. These are consent, contractual requirement, legal obligation, vital interests, public interest, and legitimate interest.

What information does the organisation collect?

The organisation collects and processes a range of information about you. This includes:

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, and references
information about your remuneration, including entitlement to benefits such as pensions or insurance cover and life insurance and authorisation to deduct from wages
swipe data for payroll purposes and on the job swipe data
insurance claims information
details of your bank account and national insurance number
information about your marital status, next of kin and emergency contacts
information about your nationality and entitlement to work in the UK
information about your passports for visa applications
information about your criminal record
details of your days of work, working hours and attendance at work
details of periods of leave taken by you, including holiday, sickness absence and reasons for the absence, bereavement leave and jury leave, unpaid leave and unauthorised absence, maternity/paternity/shared parental leave, and adoption 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, 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
GP, hospital and dentist appointment information
information on health surveillance including eyesight, lung function, hearing, dermatitis, and HAVS (hand and arm vibration)
health and safety related information including accident information, meeting notes, letters and safety footwear
photographs to identify first aiders
details of trade union membership
driving license details for driving on Company business
relevant information to allow bookings to be made with hire car companies, hotels and airlines
vehicle details for car permits
exit information when terminating employment, including redundancy, voluntary departure and restructure if appropriate
long service award information
health care plans for Simply Health
information regarding work experience
access to work information
equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

The organisation collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your-driving license; 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 organisation collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers which includes DBS Checks for security clearance. All information is permitted and required by law, the Company’s own procedures and / or those of the customers / suppliers we work with.

Data is stored in a range of different places, including in your personnel file, in the organisation’s HR management systems and in other IT systems (including the organisation’s email system).

Why does the organisation 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 benefit, pension and insurance entitlements.

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 and to enable employees to take periods of leave to which they are entitled. 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. This allows the organisation to:

run recruitment and internal promotion processes
register you to work within a country within the EEA and outside of the EEA
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, bereavement leave and jury leave, unpaid leave and unauthorised absence), to allow effective workforce management, and 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
provide references on request for current or former employees
respond to and defend against legal claims
maintain and promote equality in the workplace
maintain and monitors the usage of e-mail and internet usage for compliance

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, 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 and for health and safety purposes). Information about trade union membership is processed to allow the organisation to make union subscription deductions.

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.

Who has access to data?

Your information will be shared internally, including with members of the HR and Payroll teams, 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 organisation 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 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, the provision of benefits which includes the time & attendance system provider, provision of occupational health services, pension providers, IT outsourcing provider which also includes CCTV coverage, hire car companies, hotels and airlines, EEF for legitimate business purposes within a manufacturing environment.

Your data may be transferred to countries outside the European Economic Area (EEA), specifically to our Chinese parent Company for legitimate business purposes. Wherever possible this data is anonymised or password protected. Data is transferred outside the EEA on the basis of specified relevant safeguards. For example, declaration of adequacy, binding corporate rules or other safeguards and link to relevant documents or other information if possible.

How does the organisation 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. All paper held personal data within your Personnel File is kept secure under lock and key. All electronic records are password protected and can only be accessed by the authorised personnel. All employees are to comply with the Company Data Protection Policy and that any breaches of this policy may be dealt with using the Company Disciplinary Procedures.

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 the organisation keep data?

Your rights

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 your Director or Line Manager. You can make a subject access request by completing the organisation's subject access request form which is obtainable from HR.

If you believe that the organisation 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 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 this information, it will hinder the organisation’s ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Automated decision-making

The Company do not use automated decision-making processes.