Employment Privacy Policy

This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during your employment or engagement as a self-employed linguist or other contractor and after it ends. We are required to notify you of this information under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who collects the information

Dals (the Company) is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies, (our group companies) and so, in this notice, references to ‘we’ or ‘us’ mean the Company and our group companies.

Data protection principles

We will comply with the data protection principles when gathering and using personal information, as set out in our data protection (employment) policy.

About the information we collect and hold

We may collect the following information during your employment/engagement:

• Your name, contact details (ie address, home and mobile phone numbers, email address) and emergency contacts (ie name, relationship and home and mobile phone numbers);
• Information collected during the recruitment process that we retain during your employment;
• Employment contract information;
• Details of salary and benefits, bank/building society, National Insurance and tax information, your age;
• Details of your spouse/partner and any dependants;
• Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
• A copy of your driving licence;
• Details of your pension arrangements, and all information included in these and necessary to implement and administer them;
• Information in your sickness and absence records (including sensitive personal information regarding your physical and/or mental health);
• Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
• Criminal records information, including the results of Disclosure and Barring Service (DBS) checks;
• Information on grievances raised by or involving you;
• Information on conduct and/or other disciplinary issues involving you;
• Details of your appraisals and performance reviews;
• Details of your performance management/improvement plans (if any);
• Details of your time and attendance records;
• Information regarding your work output;
• Information in applications you make for other positions within our organisation;
• Information about your use of our IT, communication and other systems, and other monitoring information;
• Your image, in photographic and video form;
• Details of your use of business-related social media, such as LinkedIn;
• Your use of public social media (only in very limited circumstances, to check specific risks for specific functions within our organisation; you will be notified separately if this is to occur); and
• Details in references about you that we give to others.

Certain of the categories above may not apply to you if you are an independent contractor.

How we collect the information

We may collect this information from you, your personnel records, the Home Office, pension administrators, your doctors, from medical and occupational health professionals we engage and from our insurance benefit administrators, the DBS, other employees, consultants and other professionals we may engage, eg to advise us generally and/or in relation to any grievance, conduct appraisal or performance review procedure, door entry systems, swipe card systems, time management system, automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, remote access systems, email and instant messaging systems, intranet and Internet facilities, telephones, voicemail,

Why we collect the information and how we use it

We will typically collect and use this information for the following purposes (other purposes that may also apply are explained in our data protection policy (employees)):

• for the performance of a contract with you, or to take steps to enter into a contract; for compliance with a legal obligation (eg our obligations as an employer under employment protection and health safety legislation, and under statutory codes of practice, such as those issued by Acas);
• for the purposes of our legitimate interests (such as the promotion of the Company’s business interests by way of advertisement) or those of a third party (such as a benefits provider), but only if these are not overridden by your interests, rights or freedoms;
• because it is necessary for carrying out obligations or exercising rights in employment law; for reasons of substantial public interest (ie equality of opportunity or treatment or regulatory requirements); and
• to defend any legal claims that may be brought against us in connection with your employment or engagement, or to establish, bring or pursue any claim against you, eg to enforce post-termination restrictions; this will typically involve passing information on to our legal advisers, who will be subject to strict professional and contractual duties of confidentiality.
• We seek to ensure that our information collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it.

How we use sensitive personal information

“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations or exercise rights in connection with employment.
3. Where it is needed in the public interest, such as for equal opportunities monitoring.
4. Where it is necessary to protect you or another person from harm.

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

How we may share the information

We may also need to share some of the above categories of personal information with other parties, such as external contractors and our professional advisers and with potential purchasers of some or all of our business or on a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information as required to comply with the law.

“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: HR advice, occupational health assessments, pension administration, service provision messaging.

Where the information may be held

Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above. Information may be transferred internationally to other countries around the world, including countries that do not have data protection laws equivalent to those in the UK, for the reasons described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our data protection policy (employment).

International data transfers

Whenever we transfer your personal data out of the United Kingdom (UK) or European Economic Area (EEA), we ensure it is done so in accordance with the relevant data protection legislation. Where the third country does not have an adequacy decision we will put in measures ensure that your personal data is protected.

How long we keep the information for

We keep your information during and after your employment/engagement for no longer than is necessary for the purposes for which the personal information is processed. Further details on this are available in our data protection (employment) and data retention policies.

Your right to object to us processing your information

Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Please contact our data protection officer, who can be contacted dpo@dals.co.uk  if you wish to object in this way. 

Your rights to correct and access your information and to ask for it to be erased

Please contact our data protection officer, who can be contacted at dpo@dals.co.uk  if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our data protection officer for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our data protection officer will provide you with further information about the right to be forgotten, if you ask for it.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our data protection officer can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.