Employee Privacy Notice
Purpose
Sanome (Human Digital Twin Ltd t/a Sanome referred to as “Sanome”, “We, “Our” or “Us”) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the Data Protection Legislation.
Data Protection Legislation means the Data Protection Act 2018 (DPA 2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data Controller
Sanome is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under Data Protection Legislation to notify you of the information contained in this privacy notice.
We are registered with the Information Commissioner’s Office (the ICO) with registration number ZB696884. We have appointed a Data Protection Officer (DPO) to help us monitor internal compliance, inform, and advise on data protection obligations, and act as a point of contact for you (data subjects) and the ICO.
Our Data Protection Officer can be contacted at dpo@sanome.com
Scope
This notice applies to current and former employees, workers and contractors of Sanome. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
Data Protection Principles
We comply with Data Protection Legislation. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited only to those purposes
- Accurate and kept up to date
- Kept only as long as necessary for the purposes we have told you about
- Kept securely
The kind of information we hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you. Not all of these categories will apply to consultants/contractors:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
- Date of birth
- Gender
- Nationality/citizenship
- Marital status and dependants
- Emergency contact information
- National Insurance number
- Bank account details, payroll records and tax status information
- Salary, pension and benefits information
- Annual leave records
- Start date
- Location of employment or workplace
- Copy of insurance certificate and driving licence if required to drive on Company business
- Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
- Copy of passport or other national identity document
- Education details
- Employment records (including job titles, work history, working hours, training records and professional memberships)
- Compensation history
- Performance reviews and ratings
- Disciplinary and grievance information
- Letters to your mortgage company / letting agency / landlord
- Photographs
- Information about your use of our information and communications systems
We may also collect, store and use the following “special categories” of more sensitive personal information or criminal records information:
- Information about your health, including any medical condition, health and sickness records.
- Information about any criminal convictions you may declare to us.
How is your personal information collected?
We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from a recruitment agency or background checks. We may sometimes collect additional information from third parties including former employers.
We will collect additional personal information during your onboarding with us and in the course of job-related activities throughout the period of you working for us.
Situations in which we will use your personal information
The situations in which we will process your personal information are listed below.
- Determining the terms on which you work for us
- Checking you are legally entitled to work in the UK
- Paying you and, if you are an employee, deducting tax and National Insurance contributions
- Providing the following benefits to you, including liaising with the benefit providers:
- Pension
- Life Assurance
- Private Medical Insurance
- Awards such as share options and share grants (and administering your participation in related plans including communicating with you about your participation and collecting any tax and national insurance coverage due)
- Administering the contract we have entered into with you
- Business management and planning, including accounting and auditing
- Conference attendance, scientific publications and Intellectual Property filings
- Conducting performance reviews, managing performance and determining performance requirements
- Making decisions about salary reviews and compensation
- Assessing qualifications for a particular job or task, including decisions about promotions
- Gathering evidence for possible grievance or disciplinary hearings
- Making decisions about your continued employment or engagement
- Making arrangements for the termination of our working relationship
- Education, training and development requirements
- Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work
- Ascertaining your fitness to work
- Managing sickness absence and providing occupational health support
- Complying with health and safety obligations
- To prevent fraud
- To monitor your use of our information and communication systems to ensure compliance with our internal policies, e.g. our IT Policy, our Data Protection Policy, and other policies that govern the use of our systems
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
- Public relations and marketing activities, for example including photos and/or biographies on the Company website and in social media updates on LinkedIn and Instagram
- To conduct data analytics studies to review and better understand employee retention and attrition rates
- To test our apps that involve the collection of health, biomarker, and demographic information
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. 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 and in line with our Data Protection Policy
- Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our Data Protection Policy
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
- To test our apps that involve the collection of health information, biomarker data and user demographics.
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.
Our Obligations as an Employer
We will use your particularly sensitive personal information in the following ways:
- We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
- We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
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 may 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.
Information about criminal convictions
We do not envisage that we will hold information about criminal convictions, however there may be times when information about criminal convictions is processed when you declare them to us voluntarily.
This information will be stored securely and deleted at the earliest opportunity. We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests and you are not capable of giving your consent, or where you have already made the information public.
Automated Decision-Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Data Sharing
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the UK/EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: human resources support, travel booking platforms, IT and security services, payroll, pension and other financial administration services.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible acquisition or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the UK and EU
If we were required to transfer your personal information out of the UK or EU to countries not deemed by the ICO (and or European Commission as relevant) to provide an adequate level of personal information protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the data protection legislation, such as the specific contracts approved by the ICO (or European Commission as relevant) providing adequate protection of personal information.
Data Security
We have put in place measures to protect the security of your information. Details of these measures are available in our information security related policies and further details can be requested from the DPO or our Head of IT.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data Retention
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy, which is available on the HR System.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Rights of Access, Correction, Erasure, and Restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on our legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing carried out on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the DPO. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Contact Us
If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this notice, the way your personal information is processed, please contact us by one of the following means:
By email: dpo@sanome.com By post:
Human Digital Twin Ltd t/a Sanome
Fox Court, 14 Grays Inn Rd, London WC1X 8HN
You can make a complaint to the ICO (here: https://ico.org.uk/global/contact-us/) at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first using the contact details above. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.
Thank you for taking the time to read our privacy notice.
